Circular No. 24/2026/TT-BNNMT guidance on recycling and waste treatment obligations for producers and importers

On 25 May 2026, the Ministry of Agriculture and Environment of Vietnam issued Circular No. 24/2026/TT-BNNMT, providing guidance for the implementation of several provisions of Decree No. 110/2026/ND-CP regarding the recycling responsibilities and waste collection and treatment obligations of producers and importers under the Extended Producer Responsibility (EPR) framework.

The Circular applies to producers, importers, and other organizations and individuals involved in EPR implementation. It took effect on the date of its issuance.

The Circular also abolishes Article 78, Article 79, Appendix IX, and Appendix IXa of Circular No. 02/2022/TT-BTNMT, as amended by Circular No. 07/2025/TT-BTNMT. Notable changes as follows: 

Financial contribution rates and applicable products

Appendix I of Circular 24/2026/TT-BNNMT introduces significant revisions to the financial contribution rates (Fs) compared with Appendix IXa of Circular 07/2025/TT-BTNMT.

• Financial contribution rate (Fs): The Circular removes the costs associated with management, supervision, and support for recycling responsibility implementation from the calculation of the financial contribution rate (Fs).
• Covered products and packaging: The list of products and packaging subject to EPR has been revised to align with Decree No. 110/2026/ND-CP. Notable changes include: i) significant revisions to the categories of transport vehicles; ii) Clarifications and updated descriptions for several other product and packaging groups.

Templates for fulfilling recycling and waste management obligations

The Circular provides standardized forms for fulfilling recycling responsibilities and waste collection and treatment obligations.

• Forms for fulfilling EPR obligations
  • Registration and declaration form (Form No. 01, Appendix II)
  • Recycling results report (Form No. 02, Appendix II)
  • Declaration of financial contributions for waste treatment support (Form No. 03, Appendix II)
• Forms supporting recycling activities
  • Recycling support agreement (Form No. 01, Appendix III)
  • Recycling progress update (Form No. 02, Appendix III)
  • Recycling results report for recycling facilities (Form No. 03, Appendix III)
  • Recycling implementation report for Producer Responsibility Organizations (PROs) or organizations implementing recycling responsibilities (Form No. 04, Appendix III)

Conclusion

Circular 24/2026/TT-BNNMT provides businesses with a clearer legal framework for fulfilling their EPR obligations by enabling them to:

• Determine the applicable financial contribution rates for each product and packaging category;
• Use the correct reporting templates and administrative procedures;
• Prepare EPR compliance plans under the updated regulatory framework;
• Reduce the risk of errors in declarations and financial contribution payments.

Producers and importers are encouraged to review their product portfolios, identify products subject to EPR requirements, and update their internal compliance procedures to ensure regulatory compliance while optimizing compliance costs.

Related articles:

Decree No. 110/2026/ND-CP on Extended Producer Responsibility (EPR) for product and packaging recycling