14 associations propose to remove obstacles in recycling cost standards

The document, co-signed by a series of associations in different fields such as textiles, wood, seafood, milk, tea, motorbikes, automobiles, etc., clearly stated that the draft on Fs that was just submitted by the Ministry of Natural Resources and Environment to the Prime Minister on July 27 has many very high and unreasonable Fs, causing great difficulties for production and business.

According to the draft of the Ministry of Natural Resources and Environment, the associations calculate that for just three types of packaging: paper, plastic and metal, the estimated recycling fee to be paid is 6,127 billion VND per year (illustrative photo).

In the draft, some Fs are higher than the average Fs of 14 Western European countries, which are highly developed and have high costs, such as the draft Fs of aluminum is 1.26 times higher, and that of glass is 2.12 times higher...

The main reason for the unreasonably high draft Fs is that circular economy has not been applied to calculate Fs without deducting the recoverable value.

For just three types of packaging, paper, plastic and metal, the estimated recycling fee to be paid is 6,127 billion VND/year. Of which, more than 50% of the recycling fee to be paid (about 3,064 billion VND/year) is to support the recycling of high-value packaging such as metal packaging, cardboard, etc. Meanwhile, official recyclers are making huge profits without needing support.

Associations say that if this standard is issued, it will greatly affect the "health" of businesses and people's lives.

From there, the associations proposed to adjust Fs more reasonably, based on research by the Vietnam Recycling Alliance PRO, Vietnam's recycling practices and average market recycling fees.

Specifically, a coefficient of 0.1 is applied to materials whose recovered material value is much higher than the recycling cost, including metal packaging, including aluminum and iron, and paper packaging. (instead of the coefficient of 0.2 for aluminum and paper; coefficient of 0.4 for iron packaging in the draft). The reason given is that official recyclers have made a large profit without EPR. It is unreasonable to provide them with additional support, and the contribution should only be used to support the collection of products and packaging in remote areas.

For other types of packaging, the associations recommend applying Coefficient 0.3 instead of 0.6 for mixed paper packaging; coefficient 0.2 for PET hard plastic and 0.3 for HDPE hard plastic instead of 0.4; coefficient 0.3 instead of 0.6 for single-material soft packaging; coefficient 0.4 instead of 0.8 for multi-material soft packaging; coefficient 0.2 instead of 0.6 for glass packaging…

With the association's proposal, the estimated recycling fee for three types of packaging: paper, plastic and metal will decrease from VND6,127 billion to VND3,146 billion.

Suggest combining self-recycling and recycling subsidy payments

Regarding the implementation of EPR in Vietnam, the associations recommend Change the way of paying recycling contributions from advance payment at the beginning of 2024 to final settlement based on actual quantity at the end of the year (ie payment in April 2025), so that businesses can still fully fulfill their responsibilities to the environment while reducing difficulties, similar to the way of paying corporate income tax, which is paid at the beginning of the following period.

In addition, businesses are allowed to combine both self-recycling and paying recycling support fees in the same year for the same type of packaging and discarded products, instead of being forced to choose one of the two forms...

Previously, at the end of June and the end of July, many of the above issues were also mentioned by representatives of a number of associations and industries at two workshops on the content of comments on the draft Decision of the Prime Minister promulgating reasonable and valid recycling cost norms for a unit of product volume, packaging and administrative management costs to serve the management, supervision and support of the implementation of waste collection and treatment responsibilities of manufacturers and importers.

According to the provisions of the Law on Environmental Protection, starting from 2024, manufacturers and importers must fulfill their responsibility to recycle their products and packaging. To fulfill this responsibility, enterprises can choose the form of product and packaging recycling organization or make financial contributions to the Vietnam Environmental Protection Fund to support recycling.

When choosing to make a financial contribution to the Vietnam Environmental Protection Fund, the amount that the enterprise must contribute is calculated according to the formula F = RVFs. In which, F is the total amount to be contributed; R is the mandatory recycling rate of each type of product and packaging; V is the volume of products and packaging produced, brought to market and imported in the year of implementing the recycling responsibility; Fs is the reasonable and valid recycling cost norm for a unit volume of products and packaging.

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