On August 3, 2026, Pacific Environment held a specialized workshop to present a proposed study on establishing criteria for the capabilities, content, and verification methods of independent auditors regarding recycling entities’ recycling result reports. Staff members from Enviapac, EnviX’s local subsidiary, also participated in this workshop.

Several key points were shared at the workshop.

 

EPR Implementation practices and challenges in verifying recycling results

Speaking at the workshop, EPR expert – Nguyen Thi presented on the practical implementation of EPR responsibilities by businesses in Vietnam:

  • Recycling organizational models: In the early stages of implementation, most manufacturers/importers opted for third-party delegation rather than self-recycling, making EPR results entirely dependent on third parties.
  • The collection and recycling supply chain involves many different stakeholders: from collectors, sorters, transporters, pre-processors, to recyclers, etc.
  • Collection systems (e.g., plastic, paper, metal) often rely on informal networks (scrap collectors, private entities, etc.)
  • Aggregated recycling reports are compiled from various types of documentation – including contracts, weigh slips, invoices, shipping documents, operation logs, and environmental records – which are managed in a decentralized manner by multiple departments or units

 

Based on implementation experience, verifying recycling results presents challenges:

  • It is difficult to verify input volumes due to the involvement of multiple parties in the value chain
  • Risk of double-counting or underreporting of recycled volumes due to the lack of mechanisms to verify uniqueness and traceability
  • Difficulty in verifying data reliability
  • Technical factors not sufficiently addressed: technological performance, recovery rates, loss rates, and compliance with registered recycling solutions

 

Proposal to Establish Regulations for EPR Non-Financial Audits

Decree No. 110/2026/NĐ-CP stipulates the recycling responsibilities for products, packaging, and waste management obligations of manufacturers and importers, while Circular No. 24/2026/NĐ-CP provides guidance on implementing Decree 110/2026/NĐ-CP, establishing a mechanism for independent audits of recycling entities’ recycling performance reports to facilitate the disbursement of support funds for recycling activities. However, neither environmental audits nor existing financial audits are currently suitable for EPR audits.

Based on the Law on Independent Auditing No. 67/2011/QH12 and Vietnamese Standard No. 3000 (VSAE) on assurance engagements other than audits and reviews of historical financial information; along with legal provisions on EPR, several proposals regarding EPR audits have been put forward:

Competency criteria for independent audit firms:

  • Criteria for the firm: Legal status; professional competence; organizational capacity to perform assurance services for recycled financial statements; Personnel involved in performing.
  • Criteria for the quality control system: Ensuring consistency with professional standards; risk-based quality control; ensuring quality throughout the entire contract lifecycle; ensuring auditability and traceability.

Content, scope, and implementation methods:

  • Content: (i) Evaluation of the preparation and presentation of recycling quality reports; (ii) evaluation of the completeness, legality, and validity of supporting documents; (iii) evaluation of the accuracy of data; (iv) evaluation of compliance with EPR regulations; (v) evaluation of data reliability; (vi) Evaluate information and events with material impact; (vii) Evaluate the traceability of recycling results
  • Scope: Time period, subjects, location, data
  • Implementation methods: Collect audit evidence; use sampling methods that consider materiality; engage experts and utilize technology

Implementation Mechanism

  • Mandatory Entities: According to Circular No. 24/2026/TT-BNNMT, recycling result reports from entities that have signed recycling support contracts with the Vietnam Environmental Protection Fund must undergo an independent audit.
    Proposed audit requirements for recycling result reports of the following two entities:

    • Manufacturers and importers whose recycling responsibility volume or recycling results exceed the threshold specified by the Ministry of Agriculture and Rural Development
    • Recycling entities or PROs that perform recycling for multiple manufacturers, importers, or multiple organizations authorized to fulfill EPR responsibilities
  • Report requirements:
    Circular No. 24/2026/TT-BNNMT stipulates that documentation for the disbursement of support funds requires a report from an independent audit firm with an unqualified opinion. There are currently no regulations regarding reports with a qualified opinion.
  • Proposal:
    • Consider disbursing the relevant funds for assurance reports with an unqualified opinion with exceptions, provided that the scope of the exceptions does not have a ripple effect on recycling operations or other general reports
    • Do not disburse funds for reports with an adverse opinion or a disclaimer of opinion

 

Proposed EPR Audit Roadmap

Based on the study, experts have proposed the following measures for implementing EPR in the near future:

  • Develop specialized technical guidelines for EPR audits; establish a roadmap for entities required to undergo independent audits
  • Issue specialized audit guidelines for environmental/sustainable development/EPR reports; establish a registry for eligible recycling facilities and publicly list qualified audit organizations
  • Develop mechanisms for managing, supervising, and conducting post-audit quality control of audit services; establish penalties for violations
  • Develop an interconnected database: enable automatic data sharing and reconciliation between the National EPR System and the Tax Authority (electronic invoices), Customs (import/export data on scrap/products), and the electronic weighing systems/factory cameras at recycling facilities.

 

Discussion

Participants also raised several questions during the workshop:

Q1. Will businesses be audited immediately? Has the financial system met the requirements for an audit?

A1. Currently, there is only a requirement to audit the recycling results reports of entities receiving recycling support to facilitate disbursement. For financial documents that do not yet meet the requirements, substitute documents may be used for the audit. For example, in cases where invoices or supporting documents are unavailable, the business may prepare its own list of scrap quantities and origins; the auditing firm can then verify this by sending confirmation letters to individuals or business households to confirm the reported quantities.

Q2. Does the government need to review the audit report for entities receiving support?

A2. In accordance with established practices regarding other forms of support, government agencies are not required to review these audit reports, as the independent audit firm is responsible for ensuring the accuracy of the reported information. Annually, the Ministry of Finance also conducts inspections and reviews of the quality of accounting and auditing services provided by audit firms, either according to a scheduled plan or through unscheduled/random inspections based on risk criteria.