Vietnam cuts EPR contribution rates and simplifies extended producer filings for batteries, electronics, packaging, and other consumer products
HANOI, Vietnam, 25 May 2026 - Vietnam has cut a range of extended producer responsibility recycling contribution rates and simplified the filing process for manufacturers and importers under a new 2026 regulation.
Circular 24/2026/TT-BNNMT (“Circular 24/2026”), issued by the Ministry of Agriculture and Environment on 25 May 2026, introduces updated per-kilogram contribution rates for packaging, batteries, electronics, tires, lubricants, and vehicles. Circular 24/2026 repeals the earlier EPR provisions and appendices under Circular 02/2022/TT-BTNMT and replaces a more which was amended by 07/2025/TT-BTNMT. It also replaces the more fragmented reporting structure introduced in 2025 with a smaller set of consolidated forms.
The new circular took effect on the date it was signed.
Lower rates reflect removal of management costs
Under Vietnam’s environmental law, manufacturers and importers that choose to meet their EPR recycling obligations through a financial contribution, rather than setting up or joining an EPR scheme, must pay an amount calculated using the prescribed Fs rate, which represents the contribution payable for each kilogram of covered product or packaging placed on the market.
The most immediate change for businesses under Circular 24/2026 is a reduction in the prescribed financial contribution rates, known as Fs. The underlying recycling costs and adjustment coefficients remain largely consistent with the 2025 framework. However, the additional 2% management-cost component previously included in the rates has been removed.
Paper and cardboard packaging, for example, falls from VND 1,938/kg (~US$0.07 or €0.06) to VND 1,900/kg (US$0.07 or €0.06).
Flexible multi-material plastic packaging falls from VND 10,914/kg (~US$0.42 or €0.36) to VND 10,700/kg (~US$0.41 or €0.35).
| Product or packaging category | 2025 rate | 2026 rate |
|---|---|---|
| Paper and cardboard packaging | VND 1,938/kg Approx. US$0.07 or €0.06 | VND 1,900/kg Approx. US$0.07 or €0.06 |
| Rigid PET packaging | VND 1,979/kg Approx. US$0.08 or €0.07 | VND 1,940/kg Approx. US$0.07 or €0.06 |
| Flexible multi-material plastic packaging | VND 10,914/kg Approx. US$0.42 or €0.36 | VND 10,700/kg Approx. US$0.41 or €0.35 |
| Lead-acid accumulators | VND 18,278/kg Approx. US$0.70 or €0.60 | VND 17,920/kg Approx. US$0.68 or €0.59 |
| Rechargeable batteries | VND 54,876/kg Approx. US$2.09 or €1.81 | VND 53,800/kg Approx. US$2.05 or €1.78 |
Although the reductions are relatively modest, they apply across large volumes of products and packaging and may produce meaningful savings for companies with substantial EPR liabilities (e.g. those who place large volume of products on the market).
Packaging design remains a major cost driver
The revised rates continue to place a much higher financial burden on harder-to-recycle packaging.
Flexible multi-material plastic packaging attracts a rate of VND 10,700/kg, approximately US$0.41 or €0.35, compared with VND 1,900/kg, approximately US$0.07 or €0.06, for paper and cardboard and VND 1,940/kg, approximately US$0.07 or €0.06, for rigid PET.
Other rates include:
rigid PVC packaging: VND 7,760/kg, approximately US$0.30 or €0.26;
flexible single-material plastic packaging: VND 8,320/kg, approximately US$0.32 or €0.27; and
glass packaging: VND 1,980/kg, approximately US$0.08 or €0.07.
The differences reinforce the financial value of reviewing packaging materials and formats as part of product design and EPR planning.
Electronics and batteries remain among the highest-cost categories
Batteries continue to carry some of the highest contribution rates under the system.
Circular 24/2026 sets rates of:
VND 17,920/kg, approximately US$0.68 or €0.59, for lead-acid accumulators;
VND 49,800/kg, approximately US$1.90 or €1.64, for other accumulators; and
VND 53,800/kg, approximately US$2.05 or €1.78, for rechargeable batteries.
Among electrical and electronic equipment, mobile phones are subject to a rate of VND 15,960/kg, approximately US$0.61 or €0.53, while cameras and video cameras attract VND 13,560/kg, approximately US$0.52 or €0.45.
Televisions and desktop monitors carry a rate of VND 10,000/kg, approximately US$0.38 or €0.33, while covered vehicles are assigned VND 5,320/kg, approximately US$0.20 or €0.18.
Fewer forms, but detailed data still required
Whereas 2025 framework introduced separate forms for recycling plans, financial contributions, recycling results, authorized organizations, recyclers, and monthly progress reports, Circular 24/2026 replaces that structure with two main forms for product and packaging recycling obligations:
a combined registration and declaration; and
a recycling-results report for manufacturers and importers.
A separate form applies to financial contributions supporting waste treatment.
The combined filing requires companies to identify which products and packaging will be recycled and which will be covered through financial contributions. It must also include quantities placed on the market, recycling obligations, previous-year balances, recycling providers, and amounts payable.
Core EPR duties remain unchanged
Despite the streamlined forms, the fundamental compliance requirements remain consistent with existing framework prior to May 2026.
Manufacturers and importers must still determine whether their products and packaging are covered, calculate obligations using quantities placed on the Vietnamese market, and choose between organizing recycling and making a financial contribution where permitted.
They must also report recycling results, account for previous surpluses or shortfalls, and maintain detailed product, packaging, material, and weight data.
Packaging quantities must generally be reported in kilograms and calculated using the number of units placed on the market and the weight of the relevant packaging.
Management costs shift to interest earned on EPR funds
The removal of the management component from the Fs rates does not eliminate EPR administration costs. Instead, Circular 24/2026 allows those expenses to be funded from interest earned on producer and importer contributions.
Management costs for recycling support may not exceed 2% of the amount disbursed during the year. Separate limits of 0.5% and 1.5% apply to central and provincial management of waste-treatment funding.
Any remaining interest must be carried forward to support future recycling and waste-treatment activities.
Manufacturers and importers should update their EPR calculations using the 2026 rates and stop relying on the forms and totals introduced in 2025.
Companies should also verify product classifications, packaging composition, unit weights, quantities placed on the market, and previous-year recycling balances.
While the new circular simplifies the filing structure, it does not reduce the need for accurate, product-level data. For many businesses, the largest compliance risks will continue to arise from incorrect classifications, incomplete packaging information, and inaccurate market-volume calculations.
Implications for industry
Manufacturers and importers should review the new circular and update their EPR calculations using the 2026 rates and stop relying on the forms and totals introduced in 2025.
Companies should also verify product classifications, packaging composition, unit weights, quantities placed on the market, and previous-year recycling balances.
While the new circular simplifies the filing structure, it does not reduce the need for accurate, product-level data. For many businesses, the largest compliance risks will continue to arise from incorrect classifications, incomplete packaging information, and inaccurate market-volume calculations.
For business planning purposes, companies must also consider the recycling or EPR fees and the cost of collecting, maintaining, and submitting the report as part of the overall compliance cost for placing the affected products in the country.