DNVN - Commenting on the draft Decree on the pilot mechanism for developing a circular economy, VCCI requested the Drafting Committee to clarify whether there is a limit on the number of enterprises and projects that can participate in the mechanism, as well as the criteria for selecting organizations to issue green bonds, operate green bond trading floors, and voluntary carbon credits...
The Ministry of Planning and Investment is seeking comments on the Draft Decree on the pilot mechanism for developing a circular economy. The Vietnam Federation of Commerce and Industry (VCCI), after consulting with businesses and experts, has some comments.
Regarding the criteria for participating in the pilot mechanism, Article 10.2 of the draft stipulates the criteria for participating in the pilot mechanism, including: having a feasible plan and the potential to promote positive economic, social and environmental impacts; mainly using domestic input materials; (i) applying technology of the 4.0 industrial revolution. These criteria can be considered as screening criteria for selecting projects that can participate in the pilot mechanism.
However, according to VCCI, it is unclear how the state agency will evaluate the project based on the above criteria. If not, it is unclear on what basis the licensing agency will consider passing/failing or granting a license to a project but not to another project. This will be important in cases where many enterprises submit a pilot registration application. Therefore, VCCI requests that the drafting agency clarify this content.
The Ministry of Planning and Investment is seeking comments on the Draft Decree on the pilot mechanism for developing a circular economy.
Regarding the number of projects that can participate in the pilot mechanism, the draft does not have clear regulations on whether the pilot mechanism limits the number of participating enterprises. Normally, pilot mechanisms always limit a certain number of enterprises to participate in the mechanism due to the resource problem of the supervisory agency.
However, Article 12.3 of the draft stipulates that after reviewing the application, a license will be granted if the application meets the conditions and criteria. It is unclear whether this provision is understood as not limiting the number of projects that can participate in the mechanism or not? Therefore, VCCI requests the drafting agency to clarify this content.
Regarding the criteria for selecting organizations to issue green bonds and operate green bond and voluntary carbon credit trading floors, Article 17.2.b of the draft stipulates that each province or city must not have more than 5 organizations participating in the pilot mechanism to issue green bonds and only 1 unit can be associated with the local development investment fund to pilot the operation of the green bond and voluntary carbon credit trading floor.
VCCI said that it is unclear why the regulation limits only 5 organizations in each locality to issue green bonds? While every investment project has a need for capital, and projects that have entered the testing mechanism often have a need for green capital because of possible incentives.
The draft stipulates that only one unit is allowed to cooperate with a local development investment fund to pilot the operation of a green bond and voluntary carbon credit trading floor. The trading floor needs to operate centrally with the largest volume of goods (in this case, bonds and carbon credits) to ensure optimal operating costs and possible profits. Therefore, will the establishment of a trading floor in each locality create dispersion and inefficiency?
In case it remains the same, to ensure fairness and transparency, it is recommended that the drafting agency supplement regulations on criteria and identification of organizations selected to implement this content.
In addition, VCCI recommends that the drafting agency supplement regulations to clarify the content of the certificate of completion of testing; review and revise regulations allowing enterprises to use land for multiple purposes with appropriate land types...
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Source: https://doanhnghiepvn.vn/kinh-te/chinh-sach/ban-khoan-ve-so-luong-doanh-nghiep-tham-gia-co-che-thu-nghiem-phat-trien-kinh-te-tuan-hoan/20250228122614329
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