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In brief

The Ministry of Natural Resources and Environment (MONRE) released a draft decree implementing Law No. 72/2020/QH14 on Environmental Protection (“Draft Decree“), which introduces Extended Producer Responsibility (EPR). Alongside the introduction of a framework for the recycling of packaging waste (available here), the Draft Decree also proposes a mandatory recycling framework for products (“Recycling Obligations“).1

Under the Draft Decree, producers and importers subject to product Recycling Obligations will need to do either of the following:

  1. Recycle or arrange for the recycling of products according to the mandatory recycling rate and specifications.
  2. Make a financial contribution to the Vietnam Environmental Protection Fund.

The Draft Decree subjects producers and importers of products in the following categories to Recycling Obligations:

  • Electronics – including light bulbs, computers, laptops, tablets, mobile phones, cameras, video recorders, televisions, household appliances, and solar panels (recycling obligations enforced from 01/01/2024)
  • Batteries (recycling obligations enforced from 01/01/2024)
  • Oils and greases (recycling obligations enforced from 01/01/2023)
  • Inner tubes and tires (recycling obligations enforced from 01/01/2023)
  • Vehicles, Motorbikes and Heavy Equipment (recycling obligations enforced from 01/01/2025)

This alert will highlight the following topics:

  • Recycling obligations in detail
  • Product-specific recycling requirements
  • Penalties for noncompliance

 Click here to access the full alert.

1 Draft Decree implementing Law No. 72/2020/QH14 on Environmental Protection, Art. 87(2).


Phuong is a senior corporate/M&A practitioner with over 20 years of advising clients on FDI and M&A transactions in Vietnam. She has worked on deals covering a wide range of areas, including real estate, renewable energy, consumer goods and retailing, logistics, production. Over the last few years, she has established a strong reputation in the retail distribution market, having helped several global clothing brands and global retailers to establish their stores chain in Vietnam. Phuong also heads our Vietnam offices' corporate services department. An active member of the Vietnam Business Forum, Phuong has contributed comment and consultation to the drafting of major laws of Vietnam, including the current Enterprise Law and Investment Law.


Rachelle Komarnisky is an Associate in Baker McKenzie Ho Chi Minh City office.

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