Guidelines for implementing Decree No. 110/2026/ND-CP on the responsibility of manufacturers, importers to recycle products, packaging and waste treatment
July 17th, 2026
On May 25th, 2026, Decree No. 110/2026/ND-CP (“Decree 110”) detailing the implementation of several articles of the Law on Environmental Protection regarding the responsibility of manufacturers, importers to recycle products, packaging and the responsibility for waste treatment, officially came into effect. Accordingly, to guide enterprises in implementing Decree 110, the Ministry of Agriculture and Environment issued Circular No. 24/2026/TT-BNNMT (“Circular 24”) dated May 25th, 2026, detailing and guiding the implementation of several articles of Decree 110 which focuses on the Financial Contribution Rate as follows:
1. Applicable subjects
(i) Organizations and individuals manufacturing or importing products and packaging subject to the responsibility for recycling and the responsibility for collecting and treating waste (“manufacturers and importers”);
(ii) Agencies, organizations, and individuals involved in the responsibility for recycling products and packaging and the responsibility for collecting and treating waste of the manufacturers and importers.
2. The Financial Contribution Rate (Fs)
Financial contributions shall be used to support the recycling of products and packaging. The Financial Contribution Rate for a unit volume of products and packaging (Fs) is calculated based on the costs of sorting, collection, transportation, recycling and an adjustment factor.
Accordingly, the contribution rates are specified in detail in Appendix I of Circular 24, with typical cases such as:
· Paper and cardboard packaging: 1,900 VND/kg;
· Rigid PET packaging: 1,940 VND/kg;
· Rigid HDPE, LDPE, PP, and PS packaging: 3,880 VND/kg;
· Lead-acid batteries: 17,920 VND/kg;
· Engine oil, gearbox oil, and lubricants: 8,400 VND/kg;
· Rubber inner tubes and tires: 3,420 VND/kg;
· Photovoltaic panels (also referred to as solar panels): 4,000 VND/kg;
· Cargo vehicles and specialized cargo vehicles: 6,650 VND/kg.
The enterprises that choose to contribute financially instead of organizing recycling themselves shall apply a formula combining the volume of products and packaging placed on the market, the mandatory recycling rate and this applicable Fs rate to determine their financial contribution obligation.
3. Responsibilities for registering and declaring the recycling of products, packaging
Manufacturers and importers must register and declare their recycling responsibilities and report recycling results using the forms specified in Appendix II attached to Circular 24, including:
· Form No. 01 - Registration and declaration of the manufacturer’s and importer's responsibility for recycling products and packaging;
· Form No. 02 - Report on the results of recycling products and packaging by the manufacturers and importers;
· Form No. 03 - Declaration of the amount contributed to support waste treatment activities by the manufacturers and importers.
4. About submitting, receiving, managing, and filing applications for recycling support
The submission, receipt, management and opening of applications for support in recycling products and packaging are as follows:
· For direct submission: Applications are sent directly or by post to the One-Stop Service Department of the Ministry of Agriculture and Environment.
· For online submission: After the National EPR Information System has been integrated with the application submission function, applicants seeking financial support may elect to submit their application dossiers online through this System.
5. About the financial contribution accounts
The Vietnam Environmental Protection Fund shall be responsible for providing the account information for receipt of financial contributions and the payment reference details for financial contributions to support the recycling of products, packaging and waste treatment activities in accordance with the law. Manufacturers and importers making financial contributions shall transfer the contributed amounts to the designated receipt account of the Vietnam Environmental Protection Fund. This is an independent account, managed in a transparent manner and any undisbursed funds shall be deposited with a bank for the purpose of preserving the principal.
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The application of the regulations in Circular 24 needs to be coordinated with the regulations in Decree 110 and the Law on Environmental Protection 2020 to ensure compliance with the obligations and responsibilities of enterprises.
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