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1. WHAT – What does EPR actually require businesses to do?
EPR (Extended Producer Responsibility) is a policy requiring manufacturers and importers to be responsible for the collection and recycling of products and packaging after they are released to the market. According to the 2020 Environmental Protection Law and Decree 08/2022/ND-CP, amended and supplemented by Decree 05/2025/ND-CP, applicable establishments must register a recycling plan and report the results annually. If they fail to organize their own collection and recycling as required, businesses must contribute to the Vietnam Environmental Protection Fund an amount corresponding to the volume of products and packaging already released to the market.
This is a new policy that has been implemented in Vietnam in the past few years, but it is not new globally. Currently, more than 80 countries worldwide (including EU countries, Japan, South Korea, etc.) are applying this mechanism to reduce waste, and it has become an important tool for promoting waste management and the circular economy.
2. WHO – Which businesses are required to implement EPR?
According to Decree 08/2022/ND-CP, amended and supplemented by Decree 05/2025/ND-CP, there are 06 groups of products and goods, including:
- Tires and inner tubes;
- Batteries and accumulators;
- Lubricating oil;
- Products with packaging
- Electricity and electronics;
- Mean of transportation
Therefore, businesses in the following sectors and fields are likely to be subject to the EPR policy, including: food and beverages; cosmetics; pharmaceuticals; fertilizers, animal feed, veterinary medicines; cleaning products used in households, agriculture and healthcare; cement…
Certain circumstances are excluded from EPR obligations, including:
- Businesses that manufacture or import products and packaging for export, temporary import for re-export, or for research, study, or testing purposes;
- Businesses with revenue from the sale of regulated products below 30 billion VND/year;
- The company released the packaging to the market but then recalled it to repackage and reuse it for its own products.
3. WHERE – Where does EPR impact the value chain?
EPR applies to products and packaging manufactured or imported for consumption in the Vietnamese domestic market. Within the value chain, this policy primarily impacts manufacturing and importing businesses at the beginning of the supply chain, as they are responsible for ensuring the recovery and recycling of products and packaging after consumer use. This obligation can be fulfilled through self-organized recycling, authorizing recycling services, or making financial contributions as stipulated.
4. WHEN – What is the timing and implementation plan?
The timing and implementation schedule for EPR are specified for each product group and include the following specific timelines:
Roadmap for implementing recycling obligations:
- From January 1, 2024: Applicable to packaging; batteries; lubricants; and tires.
- From January 1, 2025: Applicable to electrical and electronic products.
- From January 1, 2027: Applicable to vehicles.
Key dates businesses need to keep in mind annually:
Before April 31th:
- Register a recycling plan for products and packaging that were put on the market last year.
- Report on the recycling results from the previous year.
- Declare the amount of contribution (if you choose the financial contribution option).
Before April 20th:
Pay the full amount of financial contributions to the Vietnam Environmental Protection Fund as declared.
5. WHY – Why do businesses need to proactively comply with ERP?
EPR (Emergency Response Program) has become mandatory in many countries because the traditional waste management model – in which the costs of collection and treatment are primarily borne by the State and society – is no longer suitable in the face of the rapid increase in waste, especially packaging and plastic waste. Therefore, the EPR policy is designed to shift the responsibility for post-consumer product recovery and recycling to the manufacturers and importers – the entities that bring products to market.
Businesses need to proactively comply with EPR because it is not only a legal obligation but also a crucial factor in protecting their reputation and enhancing their competitiveness in the long term.
Implementing EPR helps businesses avoid legal risks and penalties under Decree 45/2022/ND-CP, which has a maximum fine of 02 billion VND. In addition, violating establishments are required to provide and publicly disclose information. Therefore, complying with EPR also protects the image and reputation of the business, as publicly disclosing infringing information could negatively impact customer and partner trust.
From an operational perspective, EPR creates opportunities for businesses to improve their management and use of packaging materials by reviewing and digitizing the use of materials, packaging, and recycling processes, thereby optimizing the supply chain and proactively managing compliance costs. More importantly, implementing EPR helps businesses meet increasingly stringent environmental standards of the international market, while integrating circular economy principles and governance transparency into their ESG strategy, creating a foundation for sustainable development and long-term competitiveness.
6. HOW – How should businesses comply with ERP effectively?
The Environmental Protection Law and its guiding documents on EPR stipulate three compliance pathways for businesses to fulfill their obligations to recycle post-consumer products and packaging. Businesses can choose one of the three, or combine the methods below depending on their specific circumstances:
Self-organized collection and recycling: Suitable for businesses with the infrastructure, technology, and necessary permits to directly carry out the collection and recycling of products and packaging. This method is particularly suitable when businesses have a sufficiently large volume of products and packaging to collect, helping to optimize investment efficiency and shorten the payback period.
Hiring or delegating to another entity: Suitable for businesses that proactively participate in the collection and recycling network or have a large volume of products and packaging, helping to optimize costs through contracts with recycling service providers.
Financial contributions to the Vietnam Environmental Protection Fund are made according to the rates stipulated by the Ministry of Agriculture and Environment: This is suitable for businesses with small volumes of products and packaging to be recycled, which do not meet the requirements or find it inefficient to invest in their own collection and recycling systems.
Choosing a compliance method is a strategic choice, depending on factors such as the volume and category of products to be collected and recycled, as well as the sustainable development strategy of each business.
In the following article, we will analyze each EPR compliance method in detail, helping businesses understand the requirements, costs, and benefits of each option, thereby making the most appropriate and optimal decision for their specific circumstances.