Circular 24/2026/TT-BNNMT detail Decree 110/2026/ND-CP responsibilities of producers, importers for recycling products, packaging and treatment of waste

CIRCULAR

Detailing and guiding the implementation of a number of articles of the Government’s Decree No. 110/2026/ND-CP of April 01, 2026, detailing a number of articles of the Law on Environmental Protection regarding responsibilities of producers and importers for recycling of products and packaging and treatment of waste

Pursuant to the Law on Environmental Protection No. 72/2020/QH14;

Pursuant to the Government’s Decree No. 35/2025/ND-CP of February 25, 2025, defining functions, tasks, powers and organizational structure of the Ministry of Agriculture and Environment;

Pursuant to the Government’s Decree No. 110/2026/ND-CP of April 01, 2026, detailing a number of articles of the Law on Environmental Protection regarding responsibilities of producers and importers for recycling of products and packaging and treatment of waste;

Pursuant to the Government’s Decree No. 47/2020/ND-CP of April 09, 2020, prescribing the management, connection, and sharing of digital data of state agencies;

Pursuant to the Government’s Decree No. 42/2022/ND-CP of June 24, 2022, on the provision of information and online public services by state agencies in the cyber environment;

Pursuant to the Government’s Decree No. 47/2024/ND-CP of May 09, 2024, prescribing the list of national databases; the development, updating, maintenance, exploitation, and use of national databases;

Pursuant to the Government’s Decree No. 137/2024/ND-CP of October 23, 2024, defining e-transactions of state agencies and information systems serving e-transactions;

At the proposal of the Director of the Environment Agency;

The Minister of Agriculture and Environment promulgates the Circular detailing and guiding the implementation of a number of articles of the Government’s Decree No. 110/2026/ND-CP of April 01, 2026, detailing a number of articles of the Law on Environmental Protection regarding responsibilities of producers and importers for recycling of products and packaging and treatment of waste.

Article 1. Scope of regulation and subjects of application

1. This Circular details Clause 1, Article 7; Clause 2, Point a, Clause 3 and Clause 4, Article 8; Clause 4, Article 9; Clause 1, Article 10; Clause 1, Article 13; Clause 2 and Clause 4, Article 14; Clause 1, Article 15; Clause 3, Article 21 of the Government’s Decree No. 110/2026/ND-CP of April 01, 2026, detailing a number of articles of the Law on Environmental Protection regarding responsibilities of producers and importers for recycling of products and packaging and treatment of waste (below referred to as Decree No. 110/2026/ND-CP).

2. This Circular applies to:

a) Organizations and individuals producing and importing products and packaging subject to the implementation of responsibilities of recycling and waste collection and treatment (below collectively referred to as producers and importers).

b) Agencies, organizations, and individuals related to responsibilities for recycling of products and packaging and waste collection and treatment of producers and importers.

Article 2. Responsibilities for recycling of products and packaging and waste collection and treatment of producers and importers

1. The financial contribution rate per unit mass of products and packaging (Fs) is prescribed in Appendix I issued together with this Circular.

2. Forms for fulfillment of responsibilities for recycling of products and packaging:

a) Registration and declaration form for fulfillment of responsibilities of producers and importers for recycling of products and packaging, as prescribed in Form No. 01 of Appendix II issued together with this Circular;

b) Report on results of recycling of products and packaging by producers and importers, as prescribed in Form No. 02 of Appendix II issued together with this Circular.

3. Forms for fulfillment of responsibilities for waste collection and treatment:

Declaration of the amount of financial contribution for supporting waste treatment activities by producers and importers, as prescribed in Form No. 03 of Appendix II issued together with this Circular.

Article 3. Support of recycling activities of products and packaging and waste treatment activities

1. The submission, receipt, management, and opening of dossiers requesting support for product and packaging recycling activities shall be implemented as follows:

a) The dossier requesting support for product and packaging recycling activities shall be submitted in person or by post to the Single-Window Section of the Ministry of Agriculture and Environment. The dossier must be enclosed in a sealed envelope, with sealing paper affixed over the adhesive edges to ensure its integrity. The exterior shall clearly state the name of the requesting organization, the name of the dossier, and the phrase: “Dossier requesting support for product and packaging recycling activities; not to be opened prior to the dossier opening time.” Sealing paper shall be paper of high mechanical strength, bearing the signature, full name, and title of the legal representative and the seal of the organization;

b) After the National EPR Information System has integrated the function for receipt of dossiers requesting support for product and packaging recycling activities, the requesting entity may elect to submit the dossier online through such system;

c) Upon receipt, dossiers shall be managed, retained, kept confidential, and maintained with integrity and in their original condition for paper dossiers, and with data integrity for electronic dossiers, meeting information security requirements in accordance with laws. The opening of dossiers shall be implemented at a single time after the expiry of the prescribed deadline for support requests.

2. Forms for support for product and packaging recycling activities:

a) Contract for support for product and packaging recycling activities, as prescribed in Form No. 01 of Appendix III issued together with this Circular;

b) Update on product and packaging recycling progress on a quarterly basis by the supported party, as prescribed in Form No. 02 of Appendix III issued together with this Circular;

c) Report on product and packaging recycling results under the support contract by the supported party being a recycling unit, as prescribed in Form No. 03 of Appendix III issued together with this Circular;

d) Report on results of organization of product and packaging recycling under the support contract by the supported party being a producer responsibility organization, as prescribed in Form No. 04 of Appendix III issued together with this Circular.

3. Forms for support for waste treatment activities:

Report on results of use of allocated support funding for implementation of waste treatment activities by the supported provincial-level People’s Committee, as prescribed in Form No. 05 of Appendix III issued together with this Circular.

Article 4. Management and use of bank deposit interest arising from financial contributions for support of recycling activities and waste treatment activities

1. The management and use of bank deposit interest arising from financial contributions for support of recycling activities shall be prescribed as follows:

a) Annually, the Vietnam Environmental Protection Fund shall prepare an explanatory statement on the estimated amount to be disbursed for support of recycling activities during the year, the estimate of administrative expenses for the performance of responsibilities for management and use of financial contributions for support of product and packaging recycling activities, submit to the Minister of Agriculture and Environment for approval of the management expense deduction rate after obtaining the consent of the National EPR Council, ensuring that it does not exceed 2% of the amount disbursed for support of recycling activities during the year.

The amount of remaining interest after deduction of administrative expenses shall be allocated to supplement the funding source for support of product and packaging recycling activities in the following year as prescribed at Point b of this Clause;

b) The allocation of bank deposit interest must ensure transparency, objectivity, and consistency with the proportion of the support funding balance of each product and packaging group, as specified in Column 2 of Appendix I issued together with Decree No. 110/2026/ND-CP and determined according to the following formula:

Where:

i: product and packaging group i specified in Column 2 of Appendix I issued together with Decree No. 110/2026/ND-CP;

I_1i: bank deposit interest allocated to supplement funding for support of recycling activities for product and packaging group i;

_­I₁: total bank deposit interest arising from financial contributions for support of recycling activities during the year after deduction of administrative expenses;

B_1i: Total undisbursed balance of funding for support of recycling activities for product and packaging group i during the year and undisbursed financial contributions for support of recycling activities for product and packaging group i arising during the year;

B₁: Total undisbursed balance of funding for support of recycling activities for all product and packaging groups during the year and undisbursed financial contributions for support of recycling activities for all product and packaging groups arising during the year .

2. The management and use of bank deposit interest arising from financial contributions for support of waste treatment activities shall be prescribed as follows:

a) Annually, the Vietnam Environmental Protection Fund shall prepare an explanatory statement on the estimated amount to be allocated for support of waste treatment activities during the year, the estimate of administrative expenses for the performance of responsibilities for management and use of financial contributions for support of waste treatment activities, submit to the Minister of Agriculture and Environment for approval of the management expense deduction rate after obtaining the consent of the National EPR Council, ensuring that it does not exceed 0.5% of the amount allocated for support of waste treatment activities during the year.

The amount of remaining interest after deduction of administrative expenses shall be allocated to supplement the funding source for support of waste treatment activities in the following year as prescribed at Point b of this Clause;

b) The allocation of bank deposit interest must ensure transparency, objectivity, and consistency with the proportion of the support funding balance for treatment activities for plant protection product packaging and the funding for support of municipal solid waste treatment activities, the allocation formula shall be determined as follows:

Where:

j: supported waste treatment activities (j = 1, 2);

j = 1: treatment activities of plant protection product packaging;

j = 2: municipal solid waste treatment activities;

I_2j: Bank deposit interest used to supplement funding for support of waste treatment activity j;

I₂: Total bank deposit interest arising from financial contributions for support of waste treatment activities remaining after deduction of administrative expenses, and the interest amount transferred from the provincial environmental protection fund or an equivalent financial institution during the year;

B_2j: Total balance of funding for support of waste treatment activities for the group of finished plant protection product packaging during the year (where j = 1), the amount of funding for support of waste treatment activities for the remaining product groups prescribed in Column 2 of Appendix II issued together with Decree No. 110/2026/ND-CP (where j = 2);

B₂: Total balance of funding for support of waste treatment activities during the year ;

c) Annually, the provincial environmental protection fund or equivalent financial institution shall prepare an explanatory statement on the estimated amount to be disbursed for support of waste treatment activities during the year, the estimate of administrative expenses submitted to the Chairperson of the provincial-level People’s Committee for approval of the management expense deduction rate for the provincial environmental protection fund or equivalent financial institution from bank deposit interest arising from the allocated funding source for support of waste treatment activities, ensuring that it does not exceed 1.5% of the amount disbursed for support of waste treatment activities during the year.

3. Where bank deposit interest arising during the year is insufficient for deduction of administrative expenses as prescribed in this Article, the maximum administrative expense deduction shall be equal to the bank deposit interest arising during the year.

Article 5. Organization of implementation

1. The Environment Agency shall:

a) Inspect, monitor, and guide the implementation of responsibilities for recycling of products and packaging and waste treatment responsibility by producers and importers in accordance with regulations;

b) Assume the prime responsibility for, and coordinate with the Vietnam Environmental Protection Fund and relevant units in advising on the organization of appraisal and selection of supported parties for product and packaging recycling activities; advise on the organization of approving the allocation of support funding for waste treatment activities to each locality;

c) Develop, manage, and operate the National EPR Information System.

2. The Vietnam Environmental Protection Fund shall:

a) Provide receiving account information and payment transfer details for financial contributions for support of product and packaging recycling activities and waste treatment activities in accordance with laws. The receiving account must be separate from other accounts of the Vietnam Environmental Protection Fund to ensure transparency;

b) Select commercial banks and determine the deposit terms for undisbursed financial contributions for support of product and packaging recycling activities and waste treatment activities; Ensure preservation of principal, deposit efficiency, and timely disbursement for supported activities;

c) Before March 31 each year, determine the total balance of bank deposit interest and the total balance of funding for support of recycling activities and waste treatment activities as of the end of December 31 of the immediately preceding year as the basis for allocation, and carry out such allocation in accordance with Clauses 1 and 2, Article 4 of this Circular;

d) Allocate funding from administrative expenses as prescribed to serve the operations of the National EPR Council; such expenditure shall be recorded as expenses of the Vietnam Environmental Protection Fund.

3. Provincial environmental protection fund or equivalent financial institution shall:

a) Select commercial banks and determine deposit terms for undisbursed financial contributions for support of waste treatment activities, ensuring preservation of principal, deposit efficiency, and timely disbursement for supported activities;

b) After the end of the support implementation period, the provincial environmental protection fund or equivalent financial institution shall transfer the remaining bank deposit interest after deduction of administrative expenses to the Vietnam Environmental Protection Fund to supplement the funding source for support of waste treatment activities in accordance with Clause 2, Article 4 of this Circular.

Article 6. Transitional provisions

All bank deposit interest arising as of the end of December 31, 2025 shall be added to the funding for support of product and packaging recycling activities and waste treatment activities for allocation in 2026 in accordance with Clauses 1 and 2, Article 4 of this Circular.

Article 7. Effect

1. This Circular takes effect from the date of its signing.

2. This Circular repeals Article 78, Article 79, Appendix IX, and Appendix IXa issued together with the Minister of Natural Resources and Environment’s Circular No. 02/2022/TT-BTNMT of January 10, 2022, detailing a number of articles of the Law on Environmental Protection, as amended and supplemented under the Minister of Natural Resources and Environment’s Circular No. 07/2025/TT-BTNMT of February 28, 2025 and the Minister of Agriculture and Environment’s Circular No. 09/2026/TT-BNNMT of January 29, 2026.

3. Ministries, ministerial-level agencies, Chairpersons of the People’s Committees of provinces and centrally run cities, and relevant agencies, organizations, and individuals shall implement this Circular./.