The completion of this mechanism is expected to make EPR more effective in practice, create greater momentum for the recycling market, and promote the circular economy.

EPR is regarded as an important tool for shifting from the traditional waste management model towards a circular economy. Instead of the state bearing primary responsibility at the end of a product's life cycle, producers and importers are required to take responsibility for products and packaging from the time they are placed on the market through to their collection and recycling after use.

In practice, Viet Nam has gradually established an EPR framework, however, the mechanism still needs to be further refined to operate more effectively and transparently and provide stronger incentives for the collection and recycling market. The current direction of reform focuses on two major requirements: increasing the direct responsibility of businesses and removing obstacles in implementation.

One notable proposed change is the abolition of financial contributions as a means of fulfilling recycling obligations. Under the new proposal, producers and importers would be required to directly organise the collection and recycling of used products and packaging or carry out these activities through qualified entities.

According to Tang The Cuong, Director General of the Environment Department under the Ministry of Agriculture and Environment, EPR should not be viewed simply as a financial obligation for producers. More importantly, the mechanism must encourage businesses to change how they design their products, select materials, organise collection and recycling, and invest in circular economy solutions.

Under this approach, a business's responsibility does not end when a product is sold on the market. Producers must pay greater attention to the possibility of collecting products after use, how recycling is organised, the selection of partners, and the monitoring of the actual volume returned to the production cycle.

To increase flexibility, the draft regulations allow producers and importers to choose from various methods of fulfilling their recycling responsibilities, including collecting products themselves for recycling or handing them over to recycling facilities; hiring entities to collect and recycle them; authorising a producer responsibility organisation (PRO); exporting them for recycling; or combining several methods. Under the proposed roadmap, starting from 2030 for packaging and from 2033 for product groups, implementation would focus more heavily on direct collection, transfer to recycling facilities, or authorisation through PROs.

However, the shift from financial contributions to direct responsibility also requires one of the biggest current bottlenecks to be addressed: the capacity to collect products after use.

In practice, many types of post-consumer products are generated in a dispersed manner by households, individuals, agencies, and schools, while collection networks remain fragmented. According to Do Tien Doan, Deputy Head of the Waste Management Division under the Department of Environment, the draft proposes allowing producers, importers, PROs, recycling facilities, and waste treatment facilities to establish collection points either independently or in cooperation with one another. These points could accept various types of products and packaging regardless of brand.

For certain product groups that face difficulties in collection and recycling, the draft also proposes allowing outstanding volumes of unfulfilled obligations to be carried forward to subsequent years. This mechanism is intended to provide an appropriate transition period and prevent policy requirements from exceeding the market's actual capacity during the initial stage.

International experience also shows that EPR cannot be built around a rigid model. Dr Fritz Flanderka, Managing Director of Reclay Group, said there was no universal model applicable to every country. The core principle is to shift most of the responsibility for waste, particularly financial responsibility, from the state to the private sector, while the manner in which it is organised must suit each country's institutional framework, market conditions, and collection and recycling capacity.

Under Viet Nam's proposed reforms, PROs would have to meet requirements concerning their capacity to organise collection, financial capacity, electronic data management systems, and separate accounting. They would also be responsible for coordinating the collection, transportation, sorting and transfer of products to recycling facilities; managing and verifying recycled volumes; and undertaking declarations and reporting, as well as maintaining records and supporting documents and conducting independent audits.

Alongside implementation arrangements, mandatory recycling rates are also set to be established according to a long-term roadmap. The draft proposes three-year cycles, initially covering 2029–2031 and 2032–2034, with adjustments of no more than 10% in each cycle. The aim is to gradually increase recycling requirements in line with collection capacity, recycling technology, and actual conditions, while providing businesses with greater predictability so that they can plan investment.

Another issue that needs to be taken into account is the informal collection sector, which plays a significant role in waste collection and sorting in Viet Nam. International experience shows that this is also one of the major differences between Viet Nam and many European countries. Rather than leaving these workers outside the system, policies should establish mechanisms for PROs to gradually integrate them into the formal collection and recycling chain.

Francesca Nardini, Deputy Resident Representative of UNDP in Viet Nam, said the challenge was not simply to establish an EPR framework but to build a system capable of operating effectively, sustainably, and in response to market conditions. Alongside an increased role for the private sector, the state must continue to play an enabling and supervisory role. International experience shows that EPR can only work effectively when there are adequate mechanisms for licensing, reporting, verification of results, and effective sanctions. Without proper oversight, producers and PROs will have insufficient incentives to fully comply with their collection, recycling, and reporting responsibilities.

Strengthening EPR is therefore not simply a matter of revising a business obligation but of building a complete ecosystem encompassing collection, transportation, sorting, recycling, data management, and oversight. When producers' responsibilities are linked to actual collection and recycling results, EPR can become a genuine driver of the recycling market and the transition to a circular economy.