On June 28, the Vietnam Trade and Industry Confederation (VCCI) in cooperation with the Legal Department (Ministry of Natural Resources and Environment) held a workshop in Hanoi entitled “Comments on the Government Prime Minister’s Draft Decision on Recycling Costs.” Standards are intended to support the EPR – Assuming the responsibility of manufacturers and importers.

COMPANY THAT SUPPORTS ENVIRONMENT PROTECTION AND WASTE RECYCLING

In the opening remarks, Mr. Dau Anh Tuan, Deputy Secretary General of VCCI and Head of Legal Department of VCCI, said that Extended Producer Responsibility (EPR) is a mechanism that enforces the responsibility of manufacturers and importers. with waste from products and applied for the first time in Vietnam.

In recent times, the Government and the Ministry of Natural Resources and Environment have made great efforts to draft and issue documents guiding the implementation of this mechanism. In particular, the Prime Minister’s draft resolution promulgates a reasonable and valid norm of recycling costs (Fs) for a unit volume of product, packaging and administration costs at the service of management. Management, supervision and support in taking responsibility for the collection and handling of waste from manufacturers and importers is an important document.

The recycling cost norm determines the company’s contribution to the Environmental Protection Fund to support waste recycling.

This draft is not a long, voluminous document with many provisions. In fact, this draft, including the appendix, is only 5 pages long. However, these issues are relatively technical and complex, as there is a wealth of data on recycling costs across many different domains. Therefore, although the draft text is not long, the research and the proposal of cost norms Fs must be based on detailed and careful studies.

From the business perspective, Mr. Dau Anh Tuan said that VCCI and companies fully agree and support environmental protection, waste recycling and building circular economy. Companies are aware of their responsibility for this common cause and are always willing to contribute to improving the collection, treatment and recycling of waste.

At the same time, companies also believe that the EPR mechanism must be built in a sensible and effective way, by minimizing the use of packaging or changing the use of environmentally friendly materials.

Over the past period, VCCI has received many recommendations from companies and held meetings with companies to gather the views of associations and companies.

Mr. Dau Anh Tuan summarizes some of the company’s key opinions on a number of subjects. As for the calculation method and the results of calculating the amount of recycling costs, the opinions that many costs are not really reasonable, the sources of input information and the investigations are still many unclear points and have not brought many benefits. representative.

Or administration costs. Many opinions suggest taking into account the level of administrative costs in order to ensure the operation of the EPR mechanism in an economical yet effective manner.

The problem of promoting circular economy, cost Fs so far has no incentive mechanism for green raw materials and materials.

In addition, there are issues with the EPR implementation, such as B. Implementation Mechanism, Timing of Upfront Payment and Application Roadmap…

The recommended FS recycling level is very high, unbelievable

Ms. Phan Thi Bich Hanh, representative of the American Chamber of Commerce in Vietnam (Amcham), said that indeed many American companies have pioneered the field. However, according to Ms. Hanh, many proposals for recycling Fs are very high and inadequate.

Specifically: the proposed Fs for mixed paper packaging are 4.3 times higher; Aluminum is 4.9 times higher than the average F value of other countries. “This very high recycling rate will result in unreasonably high commodity prices and create difficulties for both producers and consumers,” stressed Ms. Hanh.

The Amcham representative also analyzed that the unreasonably high Fs have a key reason for not following the circular economy principle, because the value of the recovered materials was not deducted. In the Environmental Research Report of the Organization for Economic Co-operation and Development of October 28, 2021, the OECD stated: “There is a need to develop fee adjustment programs to ensure full recovery of operating costs. Move”.

Operating costs are covered from two sources: the value of the recovered materials and the contribution made by manufacturers and importers to support recycling.

As such, Amcham recommends using materials that have a recycling value greater than the cost of recycling, such as: Aluminum packaging, iron and steel, paper boxes, hard plastic packaging, means of transport, etc. If an institution is already profitable, it is necessary to adjust the adjustment coefficient of Fs = 0 according to the recommendations of the OECD.

“This is fully consistent with current collection and recycling practices in Vietnam. If that packaging and products have essentially been recycled, there is almost no risk to the environment, the support It doesn’t make sense to add even more to the recycling house that builds a profit,” Hanh stressed.

In addition, for low-value materials such as plastic packaging and mixed paper packaging, there is a need to contribute to support recyclers, but the Fs value must be reasonable and not higher than the world average.

On the other hand, according to Ms. Hanh, the administrative costs of 3% should be removed from the Fs proposal, since 3% is a very large amount, up to several hundred billion, while the government’s Decree No. 08/2022/ND -CP should be the government’s be removed. The government has regulated administrative expenses from bank profits estimated to reach several hundred billion dongs, which is quite enough for the operation of the EPR Council and EPR Office.

Ms. Chu Thi Van Anh, Vice President of the Vietnam Beer – Alcohol – Beverage Association (VBA), agreed with the above recommendations, adding that there had been no penalties in the first two years (2024 and 2025), with a focus on In the application, arrears will only be collected if the company provides insufficient or incorrect information, unless there is a willful omission to report or a willful misrepresentation.

At the same time, the proposal allows companies to combine self-recovery and payment of the recycling subsidy for one type of packaging and one product in the same year, rather than having to choose between the two methods.

In addition, the payment method will be changed from advance payment in early 2024 to final payment corresponding to the actual amount at the end of 2024 (i.e. submission in April 2025) to continue to comply with environmental responsibility, reducing the difficulties for businesses.