Recently, 14 business associations in Vietnam jointly commented on the draft decision of the Prime Minister to issue a reasonable and valid recycling cost norm and some proposals to make financial contributions. for recycling responsibility in the extended responsibility of manufacturers and importers (EPR) is effective, minimizing difficulties for businesses in the current situation.
The associations affirmed that they are always committed to supporting the Ministry of Natural Resources and Environment in efforts to protect the environment, as well as promoting the recycling of products and packaging to promote the development of green economy and circular economy. In Vietnam.
However, the cost of recycling in the draft has many unreasonable high norms because the value of recovered products has not been deducted according to the principle of circular economy, the data has many shortcomings.
According to the notes attached to the draft, Fs is calculated as the average value between two results: the recommendation of experts from the International Finance Corporation (IFC), the World Wide Fund for Nature (WWF) and the World Wide Fund for Nature (WWF). proposed by Vietnam Waste Recycling Association. These two proposals have a huge difference in the costs involved.
Moreover, the proposed Fs in the draft is not reasonable and is much higher than the average of other countries, when only the average of the two studies with the highest Fs is calculated, ignoring the other two studies with the highest Fs recommendations. Fs is much lower.
The formula for calculating Fs as in the current draft completely ignores the profit factor of the recycling business from recycled materials, or the recovery value of the packaging. Therefore, the proposed Fs does not follow the circular economy principle because the value of recovered materials has not been deducted.
The draft proposes a Fs factor of 0,3 for paper, PET bottles and aluminum; Fs 0,5 for iron and steel to reduce Fs for materials with high recovery value. This proposal of coefficient Fs is not reasonable because for materials such as iron and steel, aluminum, paper packaging, hard plastic bottles (PET), means of transport, recyclers of these materials are profitable, due to the high price. The value of recovered materials is higher than the cost of recycling.
These materials are creating jobs and profits for many workers and recycling businesses, and are mostly collected so there is little risk to the environment.
Therefore, it is not reasonable to ask manufacturers to contribute to support recyclers while those recyclers are profitable. Moreover, these are packages and products where the value of recovered materials is higher than the cost of recycling, so according to the principle of circular economy, the coefficient Fs must be zero, the associations emphasized.
The draft also classifies means of transport in the group of products that do not yet have popular recycling technology in Vietnam; or explaining the application of coefficient 1.0 to means of transport, etc., is not convincing.
The associations suggest applying a factor of zero to materials whose recovery value is higher than the cost of recycling (such as the Danish and Norwegian models). For other materials, there are separate formulas.
Many proposals Fs are very high, the risk of causing large price increases. For example, the price can increase by 1,36% for bottled water; 0,6% for canned beer; 0,2% for milk bags, causing difficulties for businesses as well as for consumers, especially in the current difficult economic context.
In order to reduce difficulties for businesses, 14 associations suggested that, in the first two years (2024 and 2025), focus on guiding the implementation, not applying penalties, only collecting underpayments if enterprises declare incomplete or incorrect (except for cases of intentional failure to declare or intentionally cheating); at the same time, allowing businesses to do a combination of self-recycling and paying for recycling support in the same year, instead of being forced to choose one of the two.
In addition, it is necessary to change the way the fund is paid; have preferential policies for environmentally friendly packaging or the use of recycled materials.
