The Ministry of Natural Resources and Environment is drafting a Decision of the Prime Minister promulgating reasonable and valid recycling cost norms for a unit volume of products, packaging and administrative management costs serving the management, supervision and support of the implementation of waste collection and treatment responsibilities of manufacturers and importers (hereinafter referred to as the draft Decision).
Recycling cost standards are still inadequate.
Speaking at At a workshop on the draft decision held by the Vietnam Chamber of Commerce and Industry (VCCI) in coordination with the Legal Department (Ministry of Natural Resources and Environment) on June 28 in Hanoi, Mr. Dau Anh Tuan, Deputy General Secretary and Head of the Legal Department (VCCI), emphasized that requiring manufacturers to be responsible for collecting, treating and recycling products (EPR) is a very progressive point in the Law on Environmental Protection. However, if the recycling cost (Fs) is not appropriate, EPR will be difficult to implement.
Overview of the workshop
Contributing to the workshop, Ms. Chu Thi Van Anh, Vice President of the Vietnam Beer - Alcohol - Beverage Association (VBA), said that in the spirit of supporting the Government in protecting the environment as well as promoting the green economy and circular economy, beverage enterprises are committed to fulfilling their responsibilities to the best of their ability, proactively researching solutions for recycling and treating specific packaging, including aluminum, glass, plastic, and paper.
However, Fs currently has many shortcomings, especially the Fs consultation studies have different results and low reliability, not suitable for the reality in Vietnam. Specifically, Fs for aluminum packaging is 6,180 VND/kg, nearly 5 times higher than the average of other countries at 1,250 VND/kg.
"Very high recycling rates lead to the risk of increased production and consumption prices, causing difficulties and affecting the competitiveness of businesses, which is not consistent with the Prime Minister's direction on removing difficulties for production, business and stabilizing people's lives," Ms. Chu Thi Van Anh emphasized.
Need a reasonable implementation roadmap
Sharing their views at the workshop, representatives of many other associations and industries said that requiring manufacturers to be responsible in EPR is a very new policy, and most Asian countries have not yet applied it as a mandatory policy. The implementation for thousands of types of packaging and products is very complicated and requires detailed guidance.
Many types of packaging and products do not have recycling technology or recycling facilities, so many businesses do not have a ready solution. If applied immediately, imposing very high fines will be very difficult and inconvenient for businesses without full guidance on the new regulations. Accordingly, there needs to be a reasonable roadmap for applying EPR.
Ms. Nguyen Cam Van, Director of Hanoi Office and External Relations of the European Business Association in Vietnam, proposed that in the first 3 years (2024 - 2026), focus on implementation instructions, not apply penalties, only collect outstanding payments if any.
"In addition, change the way of paying recycling contributions from advance payment according to the expected quantity at the beginning of 2024 to final payment according to the actual quantity at the end of 2024 (ie payment in April 2025), so that businesses can still fully fulfill their responsibilities to the environment while reducing difficulties for businesses (similar to paying corporate income tax, which is paid at the beginning of the next period).
In addition, businesses are allowed to combine both self-recycling and paying for recycling support for the same type of packaging and products instead of being forced to choose one of the two forms," said Ms. Van.
Many associations have proposed preferential policies for environmentally friendly packaging or the use of recycled materials. This will encourage businesses to use recycled materials in packaging, increase resource efficiency, reduce dependence on virgin materials in production, create output for the recycling industry and help promote the development of the recycling industry in Vietnam.
Ms. Chu Thi Van Anh, Vice President of VBA, gave her opinion at the workshop.
In this aspect, Ms. Chu Thi Van Anh shared: "The beverage industry recommends adjusting Fs appropriately for packaging using recycled materials to encourage recycling. At the same time, apply Fs = 0 to packaging and products with a recovered material value higher than the recycling cost, including paper packaging, hard plastic packaging, and metal packaging. The reason is that these packaging and products have basically been recovered and pose little risk to the environment."
Looking at the comparison of benefits between finished product enterprises and recycling enterprises, Ms. Huynh Thi My, General Secretary of the Vietnam Plastics Association, emphasized: "We should harmonize the benefits between finished product enterprises and recycling enterprises. We should not just focus on recycling enterprises but affect the large business community that is contributing a lot to the country."
In his concluding remarks at the workshop, Mr. Phan Tuan Hung, Director of the Legal Department, said he would take note of and accept the opinions.
"Regarding Fs, we will adjust it, it can be increased or decreased to be suitable and harmonious. Regarding administrative management costs, the consulting group also stated that administrative management costs are very high, we will agree and have opinions to reduce administrative costs.
After the workshop, we are still willing to listen to the opinions of associations and businesses. If associations and businesses find it too unreasonable, we are willing to invite them to the office, and someone will sit with the draft to discuss and clarify. If there are well-founded arguments, we are willing to listen and improve further," Mr. Hung emphasized.
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 an 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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