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Vietnam: EPR that is already law, and a recycling mark that is not
Vietnam applies mandatory extended producer responsibility to covered packaging, but the duty is principally recycling performance, contribution, declaration and reporting. Decree No. 110/2026/ND-CP does not prescribe a universal consumer recycling mark. The legal reference to the party responsible for labelling helps allocate responsibility; it is not itself a printing command. The Vietnam Green Label remains a voluntary certification.
The question this report answers
Vietnam’s sustainable-packaging regime is often mischaracterised as a labelling law because it assigns responsibility by reference to the party that labels or commissions packaging. In legal effect, the principal rules are extended producer responsibility obligations. Covered producers and importers must organise recycling or make the permitted financial contribution, complete declarations and reports, and retain evidence. These duties began for packaging under the staged timetable from 1 January 2024 and are now governed by the consolidated framework in Decree No. 110/2026/ND-CP, signed on 1 April 2026 and effective from 25 May 2026.
The current EPR framework does not prescribe one universal consumer recycling or EPR symbol for every covered package. Vietnam separately operates a voluntary national Green Label programme for products meeting environmental criteria and obtaining authorisation. A financial contribution to the Vietnam Environmental Protection Fund does not substantiate a claim that a specific package will be recycled. Foreign eco-labels should not be presented as Vietnamese government approval.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Packaging EPR | mandatory | Covered producers and importers fulfil recycling responsibilities directly or through the permitted financial-contribution route. |
| EPR declaration and reporting | mandatory | Obligated parties submit the prescribed information and retain supporting records under the current decree and circular. |
| Universal EPR or sorting mark | not implemented | The current EPR framework does not require every covered package to display one consumer-facing symbol. |
| Vietnam Green Label | voluntary / controlled | Products meeting the programme criteria may use the national eco-label after authorisation. |
What Decree 110 actually requires
Article 54 of the Law on Environmental Protection establishes recycling responsibility for producers and importers of products and packaging with recycling value. Circular No. 24/2026/TT-BNNMT provides forms, technical requirements and implementation detail. Packaging scope is defined by the legal categories and annexes, including packaging associated with specified product groups. Whether an exemption, size threshold, export treatment or other condition applies is a question for the current text, not for an overseas resin code. The fact that a package is recyclable or bears a foreign mark does not remove the producer’s EPR responsibility.
The 2026 decree refines responsibility for packaging manufactured to order. Where a customer orders packaging and then fills, labels or uses it to place goods on the Vietnamese market, the customer can be the party responsible for recycling rather than the packaging converter. Government implementation guidance confirms that allocation. Imported packaged goods can place responsibility on the importer defined by the legislation. This distinction matters because the converter may physically print the package while the customer or importer bears the EPR declaration and financing obligation. A foreign brand owner should not assume that responsibility is determined solely by trademark ownership.
An obligated producer or importer may organise recycling under the conditions established by law or make a financial contribution to the Vietnam Environmental Protection Fund. The selected route determines planning, documentation and settlement responsibilities. Recycling rates, specifications and contribution calculations are legal compliance measures; they are not consumer claims that may automatically be printed on the package. Declarations and reports are submitted in the prescribed form and timetable, supported by product, packaging, volume and recycling data. Businesses should use the current portal and forms under Circular No. 24/2026 rather than relying on superseded guidance issued under the earlier decree. Records should connect reported packaging quantities to customs, production and sales information.
The on-pack position, and the Green Label as a different object
Neither the EPR allocation rule nor the payment route establishes a universal on-pack EPR or sorting logo. Voluntary resin codes or disposal statements may be used only where accurate and compatible with ordinary Vietnamese product-labelling law. The Vietnam Green Label is a separate voluntary certification programme established under environmental law and implementing criteria. Authorised products may use the controlled mark for the certification period. The label indicates conformity with the applicable programme criteria; it does not replace EPR registration, declaration, recycling or contribution duties.
Environmental statements remain subject to product-labelling, advertising, standards and consumer-protection requirements. Recyclable, recycled-content, biodegradable and compostable claims should be supported by appropriate test, composition and infrastructure evidence. Environmental authorities can inspect declarations, recycling performance, contribution and claim evidence and apply the administrative consequences provided by law. Package artwork is therefore a separate workstream from EPR: ordinary product labelling first, the Vietnam Green Label only after authorisation, and no invented national sorting symbol to stand in for Decree 110.
Primary sources and verification
Government of Vietnam. Decree No. 110/2026/ND-CP detailing implementation of the Law on Environmental Protection. Official legal record
Official Gazette of Vietnam. Signed text of Decree No. 110/2026/ND-CP. Official PDF
Government of Vietnam. Circular No. 24/2026/TT-BNNMT on implementation of extended producer responsibility. Official Gazette record
Government Policy Portal. Official answer on responsibility for packaging manufactured to order. Official implementation guidance
Vietnam Environment Administration. Law on Environmental Protection 2020, including the legal basis for the Vietnam eco-label. Official English translation
Vietnamese legislation and the current annexes and forms control. Last verified: 21 August 2026.