Who Pays for the Packaging? How Vietnam’s EPR Rules Reshape Producer Responsibility in 2026
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Who Pays for the Packaging? How Vietnam’s EPR Rules Reshape Producer Responsibility in 2026

Published on: Sep 11, 2026 | Author: Marketing & Communications

Vietnam’s Extended Producer Responsibility rules answer a blunt question: who pays for packaging after consumers are done with it. Under the 2020 Law on Environmental Protection, EPR is described as producer accountability for what happens after consumption, including packaging. Sources describe EPR as no longer voluntary and now a mandatory legal obligation clarified through Decree 110/2026/ND-CP, effective from 25 May 2026. The scope is not limited to domestic manufacturers. Sources state that producers and importers placing covered products and packaging on the Vietnamese market fall within the framework, including foreign manufacturers, brand owners, and importers whose goods enter Vietnam and appear on Decree 110’s regulated lists.

Vietnam’s EPR policy has been implemented in stages. One source says obligations began on January 1, 2024 for packaging, batteries, lubricants, and tyres, followed by electronics in 2025, with vehicles arriving in 2027. The policy gives companies more than one compliance route. They can organise recycling activities themselves, hire a licensed recycler or a Producer Responsibility Organisation (PRO), or pay into the Vietnam Environmental Protection Fund. In entrusted import arrangements, one source adds that the responsible party is the one responsible for product labeling, not the logistics or customs agent. That detail matters for multinational supply chains that use contract manufacturing or outsourced import services.

How the Cost Formula Works—and Why the Inputs Matter

A key design feature is the payment formula described in sources as published, arithmetic, and auditable: F = R × V × Fs. In this formula, V is the weight of packaging placed on the market, R is the mandatory recycling rate by material, and Fs is the official recycling cost norm in dong per kilogramme. For plastic packaging, one source states R runs between 10% and 22%, with rigid PET at 22%. The same source illustrates the implication: if a company sells 100 tonnes of PET bottles, it is accountable for 22 tonnes, while the remaining 78 tonnes fall outside the obligation. That structure makes accurate declarations and evidence critical for businesses managing vietnam epr packaging recycling obligations.

The Fs component has also been debated. According to one source, at drafting consultations in late 2023, the Vietnam Recycled Plastics Association and a packaging recycling alliance asked for 3,900 dong per kilogram (about $0.15) for PET, compared with 1,900 dong ($0.07) in the draft. When the schedule was finally issued, rigid PET landed at 1,979 dong per kilogram, described as about $0.08 and roughly half what recyclers had asked for. Another source frames the wider stakes by stating Vietnam throws away 2.62 million tonnes of usable plastic annually, and that the World Bank values what is destroyed when it is buried or burned at $2.2 billion to $2.9 billion a year.

Plastic waste vs recycling
Plastic waste vs recycling
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At the same time, business incentives and packaging shifts are already visible in market forecasts. A Vietnam paper packaging market report values the market at USD 2.84 billion in 2025 and estimates growth from USD 3.11 billion in 2026 to USD 4.92 billion by 2031, at a CAGR of 9.61% (2026–2031). It also reports that containerboard held 57.18% share in 2025 and that food applications held 32.68% share in 2025. While this is market research rather than a compliance document, the report explicitly lists regulatory incentives such as EPR requirements among factors accelerating demand for paper-based formats. For compliance teams, the operational burden under Decree 110 also includes record discipline: one source advises maintaining documentation of volumes placed on the market, recycling contracts, and contribution receipts for a minimum of five years to support audits.

Who must comply with Vietnam’s EPR rules for packaging in 2026?

Sources state EPR applies to producers and importers placing covered products and packaging on the Vietnamese market. This includes foreign manufacturers, brand owners, and importers whose goods enter Vietnam and appear on Decree 110’s regulated lists.

What compliance options do companies have under Vietnam’s EPR framework?

Sources describe two main routes: organise recycling activities directly (including via licensed recyclers or PROs) or pay a financial contribution into the Vietnam Environmental Protection Fund. Companies may also combine methods depending on the category and route permitted.

How is the EPR payment calculated for packaging?

Sources give the formula F = R × V × Fs, where V is packaging weight placed on the market, R is the mandatory recycling rate, and Fs is the official recycling cost norm in dong per kilogramme. For plastic packaging, one source states R ranges from 10% to 22%, with rigid PET at 22%.

What does the vietnam epr packaging recycling debate focus on in practice?

Sources highlight that the formula is auditable, so the key debates are about the values inside it, especially recycling rates and cost norms. One source notes recyclers asked for 3,900 dong per kilogram for PET, while the issued rigid PET figure was 1,979 dong per kilogram.

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