In May 2026, the Ministry of Agriculture and Environment (MAE) issued Circular No. 24/2026/TT-BNNMT, providing detailed guidance on selected provisions of Decree No. 110/2026/ND-CP concerning Extended Producer Responsibility (EPR) for product and packaging recycling and waste management obligations of producers and importers. 

The Circular applies to producers, importers, and other stakeholders involved in implementing EPR requirements and entered into force on the date of signing. It establishes financial contribution rates, procedures for fulfilling recycling and waste management obligations, and mechanisms for providing financial support to recycling and waste treatment activities. 

The Circular also repeals Articles 78 and 79, Appendix IX, and Appendix IXa of Circular No. 02/2022/TT-BTNMT, as amended by Circular No. 07/2025/TT-BTNMT, which previously governed recycling and waste management responsibilities for producers and importers. 

Key Changes: Financial Contribution Rates and Covered Products 

The Circular introduces revised financial contribution rates (Fs) per unit weight of products and packaging, as specified in Appendix I. 

• Reduced Fs rates: Administrative, monitoring, and implementation support costs are no longer included in the calculation of Fs. Consequently, the rates are approximately 2% lower than those under the previous regulation.  

• Updated product and packaging scope: Covered categories have been revised to align with Decree No. 110/2026/ND-CP, with significant changes particularly affecting motor vehicles, packaging, batteries, lubricating oils, and tyres.  

• Clearer definitions: Several product and packaging categories have been further clarified, including coated paper and cardboard, multilayer paper packaging, flexible plastic packaging, batteries, and lubricating oils.  

• Biodegradable plastics: EPS, rigid PVC and rigid plastic packaging categories now explicitly exclude biodegradable plastics.  

• Motor vehicles: The scope has been revised, with the EPR obligation now applying to specified categories of automobiles, including cargo vehicles, passenger vehicles with nine or more seats, school buses, and certain four-wheeled motor vehicles.  

New Templates for EPR Compliance 

Circular No. 24/2026/TT-BNNMT introduces updated templates for producers and importers to fulfil their recycling and waste management obligations. 

Key submissions include: 

The updated templates require more detailed information on products and packaging subject to EPR obligations, particularly during registration and declaration. 

What This Means for Producers and Importers 

Companies subject to Vietnam’s EPR requirements should review their product and packaging classifications, applicable financial contribution rates, recycling obligations, and reporting data to ensure alignment with the new Circular. 

The updated requirements also highlight the importance of maintaining accurate product, packaging, recycling, and waste-management data to support EPR compliance and reporting.