The Government has issued Decree 110/2026/ND-CP, which introduces important changes to extended producer responsibility (EPR).
The decree retains, amends, adds to, and repeals provisions of Decree 08/2022/ND-CP (as amended by Decree 05/2025/ND-CP) and Decree 48/2026/ND-CP. In particular, the rules on who must fulfillrecycling obligationsand waste treatment obligations have changed significantly.
Subjects responsible for recycling
Compared to previous regulations, Decree 110/2026 has added a number of specific cases on subjects who must carry out recycling responsibilities to facilitate the implementation process.
These obligations apply to producers and importers placing listed products and packaging on the Vietnamese market, including packaging; batteries and accumulators; oil and lubricants; tires and inner tubes; electrical and electronic equipment; and road vehicles. Specific cases are addressed as follows:
In case products and packaging with the same brand are produced by many different manufacturers, the organization or individual responsible for labeling the goods according to the law on product and goods quality is the subject of recycling responsibility;
In case the manufacturing organization or individual is the party receiving the processing of products and packaging for the ordering party, the ordering party is the subject of the responsibility for recycling;
In case of entrusting the import of products and packaging, the organization or individual responsible for labeling the goods in accordance with the law on product and goods quality is the subject of recycling responsibility. In case the entrusted party is responsible for labeling the goods, the products and packaging put on the market are the products and packaging transferred to the entrusting party, the revenue from the products and packaging put on the market is the total import value and entrustment fee;
The organization or individual responsible for recycling is the parent company or a company with independent accounting branches authorized under the provisions of civil law to carry out recycling responsibilities for subsidiaries or independent accounting branches.
The covered packaging is commercial packaging, including direct and outer packaging, for products such as food (except chewing gum), cosmetics, medicines, fertilizers, animal feed, veterinary medicines, soaps, detergents, polishes, cleaning products, and cement, subject to the relevant product rules.
Subjects responsible for waste treatment
Under the new rules, producers and importers placing specified products and packaging on the Vietnamese market must make financial contributions to support waste treatment. These include pesticide packaging; single-use batteries; diapers, sanitary products, and disposable wet wipes; chewing gum; cigarettes; and products containing plastic.
Some specific cases are implemented as follows: In case products and packaging with the same brand are produced by many different manufacturers, the organization or individual responsible for labeling the goods according to the provisions of law on product and goods quality is the subject of financial contribution responsibility; In case the manufacturing organization or individual is the party that processes the products and packaging for the ordering party to bring to the Vietnamese market, the ordering party is the one responsible for making financial contributions;
In case of entrusting the import of products and packaging, the organization or individual responsible for labeling the goods according to the provisions of law on product and goods quality is the subject of financial contribution responsibility. In case the entrusted party is responsible for labeling the goods, the products and packaging put on the market are the products and packaging transferred to the entrusting party, the revenue from the products and packaging put on the market is the total import value and entrustment fee;
The organization or individual responsible for financial contributions is the parent company or a company with independent accounting branches authorized in accordance with civil law to carry out responsibilities for the subsidiary or independent accounting branch.
Unlike packaging covered by recycling obligations, packaging covered by waste treatment obligations refers to direct packaging under the applicable product and goods quality rules.