Vietnam is advancing significant revisions to its Extended Producer Responsibility framework, with the proposed changes shifting the compliance model from financial contributions toward direct, measurable recycling and collection activity. The move carries considerable implications for textile, apparel, and retail supply chains operating in or sourcing from the country, particularly around packaging decisions, material choices, reverse logistics strategies, and partnerships with recycling organisations.
Shifting Responsibility from Payments to Action
Under the existing EPR framework, businesses could meet recycling obligations largely through financial payments. The revised draft proposes to remove this route entirely. As reported by Vietnamese media, producers and importers would instead be required to organise the collection and recycling of their used products and packaging either independently or through qualified organisations.
This change directly ties compliance to actual recycling outcomes rather than monetary contributions, making the Vietnam EPR framework more results-oriented in its approach to waste management.
Compliance Pathways Under the Draft
The draft regulation outlines several compliance routes available to businesses. These include organising collection and recycling operations directly, contracting with licensed recycling companies, authorising Producer Responsibility Organisations (PROs), exporting products for recycling where applicable, or combining multiple methods to fulfil recycling obligations.
This flexibility in compliance structure is intended to accommodate businesses of varying sizes and operational capacities while ensuring that actual recycling activity remains at the core of the obligation.
Building an Ecosystem for Circular Economy Transition
Vietnam has been developing its EPR framework incrementally, but regulators have identified that further reform is necessary to improve both effectiveness and transparency. The current proposals are centred on two key priorities: raising the direct responsibility of producers and importers, and addressing practical difficulties encountered during implementation.
The revised framework is designed to support a broader operational ecosystem that spans collection, transportation, sorting, recycling, data management, and regulatory supervision. This comprehensive approach reflects the country’s broader ambition to advance its circular economy by moving waste management away from a predominantly state-led end-of-life model.
Under the revised direction, EPR is being positioned as a structural tool through which producers and importers carry responsibility from the point of market entry right through to post-use collection and recycling, reinforcing the circular economy principle at every stage of a product’s lifecycle.
Implications for Textile, Apparel, and Retail Supply Chains
For businesses operating within textile, apparel, and retail supply chains, the proposed direction introduces direct relevance to operational decisions. Packaging choices, material sourcing, reverse logistics planning, and the selection of recycler partners would all need to align with compliance requirements under the revised Vietnam EPR framework.
As recycling obligations become more closely linked to demonstrated recycling results rather than financial substitutes, supply chain operators would need to establish or deepen their engagement with PROs and certified recycling organisations to maintain compliance.
Strengthening the Recycling Market
A central intended outcome of the revisions is to strengthen Vietnam’s recycling market by channelling producer responsibility into tangible collection and processing activity. By requiring businesses to directly engage with the recycling ecosystem rather than simply contributing financially, the framework aims to stimulate demand for recycling services, improve data visibility, and create a more accountable system of waste management.
The proposed changes are framed as an effort to make producer responsibility genuinely functional in advancing Vietnam’s transition toward a circular economy, with measurable recycling outcomes serving as the benchmark for compliance.
