On April 1, 2026, the Government issued Decree No. 110/2026/ND-CP regulating recycling responsibilities for products and packaging, as well as waste treatment obligations of producers and importers (EPR). The Decree takes effect on May 25, 2026, and amends and supplements previous provisions under Decree No. 08/2022/ND-CP (as amended by Decree No. 05/2025/ND-CP and Decree No. 48/2026/ND-CP).

The EPR Decree further strengthens the legal framework for waste management and promotes the circular economy in Vietnam. 

Entities subject to EPR obligations
The Decree clarifies and supplements several specific cases:

• Products and packaging under the same brand with multiple manufacturers: the entity responsible for labeling the goods shall fulfill the recycling obligation.
• Contract manufacturing: the contracting party shall be responsible for EPR compliance.
• Import entrustment: the entity responsible for labeling the goods shall fulfill EPR obligations. Where the entrusted importer labels the goods, the products and packaging placed on the market are those transferred to the entrusting party; revenue is calculated as the total import value plus entrustment service fees.
• Parent companies or companies with independently accounted branches may be authorized to fulfill recycling obligations on behalf of subsidiaries or such branches.

Recycling rates and Product/Packaging categories

According to Appendix I, mandatory recycling rates for products and packaging remain mostly unchanged compared to previous regulations. However, the category of road transport vehicles has been revised. Motorcycles and mopeds are no longer subject to mandatory recycling, while the focus shifts to automobiles such as cargo vehicles, passenger vehicles with 9 seats or more, and certain specialized vehicles. 

Mandatory recycling rates will be adjusted every three years, with an increase of no more than 10% per adjustment cycle; the first adjustment is expected from 2029.

The financial contribution amount to support recycling activities for each product and packaging (Fs), issued by MAE, is also adjusted every three years; the first change will be in 2029.

Forms of fulfillment of recycling responsibility

The methods of fulfilling recycling obligations remain consistent with the Law on Environmental Protection, including self-organized recycling; or financial contributions to the Vietnam Environmental Protection Fund.

The Decree also removes provisions on eligibility conditions for Producer Responsibility Organizations (PROs). 

Financial contributions for waste treatment support

For products and packaging containing hazardous substances, difficult-to-recycle materials, or those posing challenges for collection and treatment, the Decree requires financial contributions to support waste treatment activities.

Financial contribution amounts and applicable subjects largely remain unchanged, with an adjustment roadmap set every five years, with increases not exceeding 15% per cycle, starting from 2031.

Supplementary provisions on support for recycling and waste treatment activities

The Decree introduces specific provisions on support mechanisms for recycling activities for recyclers and PROs, as well as waste treatment support for provincial-level People’s Committees. These are detailed in Chapters IV and V of the Decree.

Transitional provisions

EPR obligations applicable up to the end of 2025 shall continue to follow previous regulations. From 2026 onwards, recycling and waste treatment responsibilities shall be implemented in accordance with Decree No. 110/2026/ND-CP.

Conclusion
Decree No. 110/2026/ND-CP provides a clearer and more transparent legal framework for the implementation of EPR in Vietnam. EPR compliance not only helps businesses meet regulatory requirements but also supports the transition toward sustainable production models and enhances competitiveness in the context of a growing circular economy.

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Amendment to the Decree on Greenhouse Gas Emission Reduction and Ozone Layer Protection