Vietnam Public consultation for draft regulations of GHG and ODS organized in Vietnam

The Vietnam Chamber of Commerce and Industry (VCCI), in collaboration with the Ministry of Natural Resources and Environment (MONRE), held a webinar on July 1, 2021 on collecting opinions on the draft Governmental Decree on greenhouse gas reduction and ozone layer protection. The webinar was chaired by Mr. Du Anh Tuan, Director of VCCI Legislative Department, and was attended by various experts, business associations, and representatives of relevant companies. The seminar began with a presentation by Mr. Tang The Cuong, Director of the Department of Climate Change of MONRE and Mr. Pham Quoc Huy, Head of the Greenhouse Gas Emissions Division on “Commentary on the draft Governmental Decree on greenhouse gas reduction and ozone layer protection”. The discussion and Q&A session with the participants followed.

The draft decree is the first comprehensive rules on greenhouse gas reduction in Vietnam, and stipulates the inspection and reduction of greenhouse gas emissions for specific facilities and the establishment of a domestic carbon market. It also includes rules on management of ozone-depleting substances.


Comments from participants

The comments made during the webinar were mainly about the feasibility of the proposed decree and requests for its implementation, specifically as follows:

  • Clarify the regulated companies that must implement greenhouse gas reduction.
  • Provide detailed guidance on how to calculate carbon dioxide (CO2) emissions by sector.
  • Provide training to companies for accurate calculation of carbon dioxide (CO2) emissions.
  • Provide grace period for greenhouse gas testing and reporting.
  • Adjust reporting periods appropriately to allow sufficient time for the collection of data.
  • Provide more detailed explanations of technical terms, as the climate change field is new and highly specialized.


Questions and Answers

Some examples of Q&A in this webinar are as follows:

Q: According to the roadmap, greenhouse gas testing will be conducted from 2021 to the end of 2025. The period of 5 years seems to be too long.
A: In other developed countries, the first greenhouse gas inspections were also conducted for about five years, which is an important period for the Vietnamese state administration to build up a database of GHG emissions of enterprises.


Q: When will the quotas for the production and import/export of controlled ODS be allocated to companies?
A: In accordance with Article 27(2) of the draft decree, it will be stipulated that the competent authorities must determine the quota for the manufacture and import/export of controlled ODS by February 28 of each year.


Q: In accordance with Article 23(3)(a) of the draft decree, the quota for the production of HFCs will be determined by the average of the production volumes in 2020, 2021 and 2022. However, in the current complex situation in the COVID-19, can the average of these three years reflect the real domestic production and consumption of HFCs?
A: The years 2020, 2021, and 2022 are the base years that countries participating in the Montreal Protocol have to comply with. Vietnam is not an exception. In accordance with Article 23.3, the baseline values for production and consumption of HFCs are specified as follows

  1. The baseline for the production of HFCs is the average of the production in 2020, 2021 and 2022.
  2. The baseline for the consumption of HFCs is determined by adding the average of the CO2-equivalent consumption in 2020, 2021 and 2022 to the baseline for the CO2-equivalent consumption of HCFCs by 65%.

However, these aggregated data will include new importers or planned importers.

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting


MSc in Earth Science, The University of Tokyo

AOKI Kenji