Sending petitions to 9 Ministers, 14 associations said that the draft imposes "unreasonably high" recycling costs, higher than some European countries.
The 14 associations making the recommendations include: Transparent Food; Ho Chi Minh City Food and Foodstuffs, Vietnam Seafood Processing & Export; Vietnam Milk; High-quality Vietnamese Goods Enterprises; Vietnam Beer - Wine - Soft Drinks; Vietnam Textiles; American Enterprises in Vietnam; Vietnam Wood & Forestry Products; Vietnam Tea; Vietnam Motorcycle Manufacturers; Vietnam Automobile Manufacturers; Vietnam Plastics; Enterprises Producing & Trading Plant Protection Products.
The draft recycling cost norms were submitted to the Prime Minister by the Ministry of Natural Resources and Environment in July. According to associations, the draft has many unreasonably high recycling norms (Fs), causing difficulties for production and business. Fs includes costs for sorting, collecting, transporting, recycling packaging products and administrative management costs to support the implementation of recycling responsibilities of manufacturers and importers.
The associations said that some recycling costs are higher than the average of 14 Western European countries, which are developed and expensive. For example, aluminum shells and packaging are 1.26 times more expensive to recycle; glass is 2.12 times more expensive. According to the associations, recycling costs should only be 30-50% of those in Western European countries because the cost of raw materials and technology may be the same, but labor costs in Vietnam are only one-tenth of those in these countries.
According to the associations' estimates, for just three types of packaging: paper, plastic, and metal, the recycling fee is estimated at VND6,127 billion a year. Of which, more than 50% of the fee (about VND3,064 billion a year) is to support the recycling of high-value packaging such as metal packaging and cardboard.
This is considered inappropriate when the current recycling cost has not deducted the price of recovered materials, which means ignoring the profit factor of businesses recycling materials or recovering packaging. In fact, materials with high recovery value such as iron, steel, aluminum, and hard plastic bottles when processed by businesses all bring high profits. For example, with aluminum can recycling, associations said, official recyclers earn about 700-1,286 billion VND a year.
"It is unreasonable for businesses and consumers to have to pay thousands of billions of dong more to support recyclers who are making huge profits," the associations commented.
In addition, this large expense will cause many difficulties for businesses in the context of economic difficulties. People's wallets are also affected when commodity prices increase. Therefore, the associations propose to adjust the recycling rate more reasonably.
The associations also proposed to remove shortcomings in the implementation of recycling contributions in Vietnam. For example, changing 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 environmental responsibilities but reduce pressure - similar to the way of paying corporate income tax is paid at the beginning of the following period.
Businesses also hope to be allowed to combine both self-recycling and paying for recycling support in the same year for the same type of packaging and discarded products, instead of being forced to choose one of the two forms; There are preferential policies for environmentally friendly packaging, or using recycled materials.
The VCCI representative previously also supported environmental protection, but wanted to contribute ideas for appropriate recycling rates. Because without feasible rates, the extended producer responsibility policy cannot be effectively implemented.
The EPR Office (the unit that organizes, manages, supervises and supports the implementation of product and packaging recycling responsibilities and waste collection and treatment responsibilities of manufacturers and importers) said that the method of determining recycling cost norms has been surveyed at many facilities. The results show that actual recycling costs vary between facilities due to many factors such as technology, equipment, country of origin, output products, and input scrap quality requirements. This leads to differences in proposed related costs between groups.
Recycled products according to specifications require different levels of investment in technology and equipment, resulting in different recycling costs. Enterprises that produce recycled products directly from waste products and packaging will have much higher recycling costs than those that produce raw materials for production. Therefore, Fs is proposed to be determined based on the calculation of the production cost standards for basic products of the recycling process on the principle of support.
According to the Law on Environmental Protection, from January 1, 2024, manufacturers and importers must fulfill their responsibility to expand the recycling of discarded products and packaging. Enterprises can choose the form of product and packaging recycling organization or contribute financially to the Vietnam Environmental Protection Fund to support recycling.
The Ministry of Natural Resources and Environment is the agency assigned to issue specific recycling rates for each type of product and packaging, with an adjustment cycle of every three years. This agency submitted the draft to the Prime Minister in July.
Duc Minh
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