Vietnam Vietnam discloses draft circular for introducing PRTR

15 industries covered, such as chemicals and batteries

The draft “Circular on environmental protection for chemicals, plant protectants and veterinary medicines” was released in Vietnam on March 23, 2017. The draft, which was developed subject to Articles 59 and 67 of the Law on Chemicals (No. 06/2007/QH12), and Article 74 and 78 of the Law on Environmental Protection (No. 55/2014/QH13), requires business establishments to keep record and notify release and transfer of pollutants. This regulation seems to correspond to the so-called “PRTR “.


Business establishments subject to PRTR regulations

The industry categories subject to the draft are set out in Annex 15, which consists of the following:


Regulated industry

1 Cement and clinker
2 Thermal power plant
3 Rare earth and radioactive minerals development
4 Solid mineral development and processing that use toxic chemicals or industrial explosives
5 Processing and refining of non-ferrous metals, radioactive metals and rare earth minerals
6 Concentration plants for rare earth and radioactive minerals
7 Oil and gas mining
8 Petrochemical refineries (excluding LPG extraction and filling and lubricating oil processing businesses)
9 Solid and hazardous waste recycling plants
10 Centralized urban wastewater treatment plant or centralized industrial wastewater treatment plant
11 Chemical fertilizer manufacturing plants
12 Plant protection chemicals manufacturing plants
13 Chemicals, resins, resin products, and paints manufacturing plants
14 Detergent and additive manufacturing plants
15 Pulp and paper manufacturing plants that use raw materials
16 Spinning or dyeing plants
17 Liquid rubber processing plants
18 Cells or batteries manufacturing plants


Main requirements

Establishments that are fall into the industrial type specified in Annex 15 ,which is shown as the above table, and have more than a specific capacity must calculate the type and quantity of pollutants that would be discharged to each environment, such as air, soil and water, or that are transferred in the form of solid waste. The calculation of pollutant emissions must follow one of the methods below:

  1. Calculations based on actual observations;
  2. Calculations based on material balance;
  3. Calculations based on emission factors.

The notification contents of emission transfers of pollutants specified in this draft consist of the following:

  1. The type and amount of pollutants discharged into each environment, such as air, water, and soil;
  2. Solid waste to be buried at the business establishments;
  3. The type and amount of pollutants in wastewater that are transferred to other sites for collection into the wastewater system; and
  4. The types and amount of pollutants contained in conventional and hazardous solid waste and transferred off-site for treatment, reclamation, and material recovery purposes.

Each establishment must notify pollutant emission transfers along with an environmental monitoring report and submit periodic reports to the local Department of Natural Resources and Environment. The form of the pollutant emission transfer notification is specified in Annex 16 of this draft.

The substances subject to this PRTR scheme are defined in Annex 1, including benzene, methane, sulfur hexafluoride, various heavy metals, and various organic halogen compounds.

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