Vietnam is introducing mandatory recycling obligations for producers and importers, marking an important step in the country’s transition toward extended producer responsibility and circular packaging systems. From 25 May, companies placing certain products and packaging on the Vietnamese market will be required either to organise recycling themselves or contribute financially to the Vietnam Environmental Protection Fund.

The new requirements are set out under Decree 110/2026 and apply to a broad range of materials and products, including paper, carton, plastic, metal and glass packaging, as well as tyres, electronic devices, batteries, accumulators and lubricants. The rules are designed to make producers and importers more directly responsible for the waste generated by the products and packaging they sell.

The regulation comes at a critical time for Vietnam’s waste management system. According to data cited by Vietnam Investment Review from the World Bank and Vietnam’s Ministry of Agriculture and Environment, the country generates around 3.5 million tonnes of plastic waste each year, but only 33% is recycled. Average plastic waste generation is estimated at 37-41kg per person annually.

Vietnam’s new recycling fee system shifts packaging waste responsibility upstream, linking producer obligations to the volume and type of materials placed on the market.

The environmental stakes are significant. Around 65% of plastic waste in Vietnam is estimated to be at risk of leaking into rivers, lakes, canals and seas, or being discharged directly into the environment. This creates pollution risks for land, water and air, while increasing pressure on municipalities and informal waste systems.

Under the decree, mandatory recycling rates are calculated according to the minimum share of products or packaging that must be recycled relative to the total volume placed on the market in a given year. For packaging producers, the rates vary by material. Aluminium packaging and rigid PET plastics are subject to a 22% recycling obligation, while paper, carton and ferrous metal packaging are set at 20%.

• Aluminium and rigid PET packaging must meet a 22% mandatory recycling rate.
• Paper, carton and ferrous metal packaging are subject to a 20% rate.
• Companies may recycle directly or pay into the Vietnam Environmental Protection Fund.
• Rates will be reviewed every three years, with the first revision scheduled for 2029.

For packaging companies, the regulation creates a new compliance and cost framework. A company placing 100 tonnes of aluminium or rigid PET packaging on the market annually would be required to recycle at least 22 tonnes. Businesses that do not manage recycling directly will need to calculate financial contributions based on the volume placed on the market, the mandatory recycling rate and standard recycling costs per unit.

The decree gives companies two main compliance routes. They may organise recycling activities themselves, hire professional recyclers or authorise intermediary organisations to collect and recycle products on their behalf. In these cases, recycling plans and annual reports must be submitted through the National Information System before 1 April each year.

Alternatively, companies can fulfil their obligations through financial contributions to the Vietnam Environmental Protection Fund. Payments must be made annually before 20 April and will be used to support recycling activities nationwide. This mechanism is intended to strengthen recycling capacity while giving businesses a practical route to compliance.

The regulation also includes exemptions for smaller businesses. Producers and importers with annual revenue below approximately USD 1.2 million from products and packaging subject to recycling obligations will be exempt. Products manufactured for export or temporarily imported for re-export are also excluded.

For Vietnam’s packaging industry, the new EPR framework could reshape material choices, packaging design and supplier relationships. Producers will need better data on packaging volumes, material composition and recyclability. Recyclers and collectors may also see new opportunities as demand grows for verified recovery and processing services.

The biggest challenge will be implementation. Recycling obligations can only deliver real circular economy benefits if collection systems, sorting infrastructure, reporting tools and recycling markets are strong enough to handle the required volumes. For materials such as PET, paper and aluminium, higher recovery rates may be achievable if investment follows the regulation.

Vietnam’s move reflects a wider regional and global trend: packaging waste is increasingly being treated as a producer responsibility issue rather than only a municipal waste problem. As EPR systems expand, companies that sell packaged goods in multiple markets will need to build stronger compliance systems and design packaging that performs not only for consumers, but also for recovery and recycling after use.