Decree 110/2026/ND-CP (issued on April 1, 2026, effective from May 25, 2026) regulates in detail the responsibilities of manufacturers and importers for recycling products, packaging and waste treatment under the EPR mechanism.
Decree 110/2026/ND-CPdetails Article 54Environmental Protection Lawon the responsibility to recycle products and packaging and Article 55 of the Law on Environmental Protection on the responsibility to collect and treat waste of organizations and individuals producing and importing (English abbreviation is EPR).
Decree 110/2026/ND-CP applies to:
– Organizations and individuals that produce and import products and packaging are subject to recycling responsibilities and waste collection and treatment (collectively referred to as manufacturers and importers).
– Agencies, organizations, and individuals related to the responsibility of recycling products and packaging and the responsibility of collecting and treating waste of manufacturers and importers.
According to Clause 1, Article 4 of Decree 110/2026/ND-CP, manufacturers and importers of products and packaging on the list must carry out recycling according to mandatory rates and specifications when placed on the Vietnamese market.
Article 5 defines the mandatory recycling rate as the minimum volume to be recycled relative to the total volume of products and packaging placed on the market. Appendix I sets the rates, which may increase every three years from 2029, by no more than 10% each time.
Under Article 6, businesses may recycle themselves, hire a recycler, or authorize an organization to fulfill their recycling obligations. Implementing entities must hold the required environmental permits.
If they do not organize recycling, businesses must contribute to the Vietnam Environmental Protection Fund using the formula F = R × V × Fs under Clause 1, Article 8. Declarations are due before April 1 and payments before April 20 each year under Clause 3.
In addition, Clause 1, Article 7 requires businesses to register plans and report annual recycling results on the National EPR Information System before April 1 every year.
Some cases that do not require recycling are specified in Clause 3, Article 4, such as products for export, revenue of less than 30 billion VND/year or packaging that has been recovered at the prescribed rate.
According to Article 24, the above regulations officially apply from May 25, 2026 to product recycling, packaging and waste treatment activities from 2026 onwards.
Thus, from May 25, 2026, regulated enterprises are required to carry out recycling responsibilities according to the EPR mechanism or make financial contributions according to regulations.
Author: Ngoc Thuy, citingVietnamese Law
EPR and key considerations for businesses
How to Meet Packaging Recycling Obligations Under EPR
EPR mechanism is an important topic for businesses that produce, import and use plastic packaging during the transition to a circular economy. As the market demands more transparent material sourcing, businesses need to understand the impact of the EPR mechanism on product design, collection operations, reporting data and recycling partner selection. Early preparation helps reduce compliance risks and creates a competitive advantage when customers prioritize products with recycled content and a clear environmental story.
From an operational perspective, the EPR mechanism should not be viewed as a separate task of the legal or environmental department. Businesses need to connect purchasing, production, logistics, sales and recycling partners to form a unified data flow. Information on material types, generated volumes, recovery rates, recycling documents and output quality need to be standardized from the beginning to make inspection, reporting and cost optimization more convenient.
Eco Revive supports practical EPR solutions for collecting, sorting, and recycling plastic packaging and supplying recycled plastic pellets. For PE materials, effective recycling depends on properly sorted feedstock, consistent processing, and transparent output data. This can help businesses document their efforts to reduce emissions and material costs and respond to market requirements.