1. This article is about operations, not about applying for a permit
This article covers the period after a farm is already operating: how waste generated in the sheds each day must be collected, treated and discharged in compliance with the law. It continues the article on environmental permits for livestock farms (post 172024), whose section 8 summarised post-permit obligations in a single short passage. This article does not explain how to apply for an environmental permit, does not explain environmental registration, and does not replace the article on penalties under Decree No. 211/2026/ND-CP. Readers need to keep three questions separate: whether the farm holds the required environmental paperwork, whether its treatment system meets the standards in daily operation, and which penalty framework applies to which violation. Confusing the three leads to costly mistakes — for example, a permitted farm that discharges above the standard is still sanctioned, and a farm that fails to treat waste properly must not have the penalty for operating without a permit applied to it.
The main legal framework, checked for validity on 27 October 2026, comprises: the Law on Environmental Protection 2020 (Law No. 72/2020/QH14, effective from 1 January 2022); Decree No. 08/2022/ND-CP guiding that Law (issued 10 January 2022, effective the same day; amended by Decree No. 05/2025/ND-CP); Circular No. 02/2022/TT-BTNMT guiding the Law (amended by Circular No. 07/2025/TT-BTNMT); the Law on Animal Husbandry 2018 (Law No. 32/2018/QH14); Decree No. 13/2020/ND-CP guiding the Law on Animal Husbandry; Decree No. 45/2022/ND-CP on administrative penalties in the environmental field; Decree No. 211/2026/ND-CP on administrative penalties in animal husbandry (issued 16 June 2026, effective 5 August 2026); and national technical regulation QCVN 62-MT:2016/BTNMT on livestock wastewater (issued with Circular No. 04/2016/TT-BTNMT, effective 15 June 2016, still in force at the date of writing).
2. Sort the waste streams before talking about treatment
A livestock farm generates several waste streams at once, and each needs different management. Dumping everything into one pit and discharging it is wrong from the first step, because a wastewater system cannot handle unseparated solid manure, and a composting area cannot receive wash water that has not been settled. Four streams must be separated at source:
- Organic solid waste: animal manure, bedding material, leftover feed. This stream can become fertiliser or aquaculture feed after treatment, but only after treatment meeting the standards — never used untreated.
- Wastewater: shed wash water, cleaning water, wastewater from livestock areas, and domestic wastewater from the facility if it is connected to the livestock wastewater system. This stream is governed by QCVN 62-MT:2016/BTNMT when discharged into a receiving water body.
- Exhaust gas, odour and dust: odour from sheds, manure storage and treatment systems; dust from feed, bedding and on-farm transport. Odour is controlled by correct operation, safe distances and treating the source, not by visual inspection.
- Hazardous waste and dead animals: veterinary medicine packaging, syringes, disinfectant chemicals, and dead animals — especially animals that died of disease. This group must never be mixed into ordinary waste streams and must be managed under animal health and environmental protection rules.
For organic solid waste, Clause 2, Article 59 of the Law on Animal Husbandry 2018 sets three routes: the farm owner is responsible for treating organic solid waste to meet national technical regulations before using it as plant fertiliser or aquaculture feed; untreated organic solid waste must be moved out of the farm to a treatment site by dedicated equipment and vehicles; animals that died of epidemics and other hazardous waste must be handled under animal health and environmental protection law. In short, “compost then apply” is lawful only when composting and treatment have met the standard, and “haul it away” is lawful only when dedicated vehicles take it to a treatment site, not to another dumping spot.
3. Solid waste treatment: composting, biogas and conditional reuse
For organic solids, farms commonly combine aerobic composting, biological bedding and biogas digesters. Each has a distinct role: biological bedding reduces odour and keeps manure dry inside the shed; aerobic composting turns manure into fertiliser through a controlled process of temperature, moisture and composting time; a biogas digester treats manure and organic-rich wastewater while capturing biogas for cooking or power. Technology should be chosen on actual waste volumes, animal type, land area and long-term operating capacity, not on advertising. An overloaded digester overflows, leaks and becomes a new pollution source; an uncovered composting area without a leachate channel lets leachate seep into soil and nearby water.
The decisive legal condition for reuse is that treated products may be used as fertiliser or aquaculture feed only after meeting national technical regulations (Clause 2, Article 59 of the Law on Animal Husbandry 2018). Farms should keep records of the composting process, composting time, input and output volumes, and where treated products are used. When inspectors ask whether manure has been treated to standard, the answer must be records and results, not assurances. Storage areas must also respect safe distances: under Article 5 of Circular No. 23/2019/TT-BNNPTNT, the minimum distance from a small farm to a residential area is 100 metres, from a medium farm 200 metres, and from a large farm 400 metres; to schools, hospitals, markets and community domestic water sources the minima are 150 metres for a small farm and 500 metres for a large farm, while to schools, hospitals and markets the minimum is 300 metres for a medium farm (community domestic water sources are not listed for a medium farm); the minimum distance between two farms of different owners is 50 metres. Distances are measured from the shed or the waste storage area, so where the manure store sits matters as much as where the shed sits.
4. Wastewater treatment: separation, settling, biogas and post-biogas treatment
Livestock wastewater is high in organic matter, nitrogen and pathogens, so it cannot be discharged directly after a single settling tank. A typical chain has four stages: coarse solids separation (screens, manure separation); settling and flow equalisation; anaerobic treatment in a biogas digester that sharply reduces organic load; then post-biogas treatment — biological ponds, constructed wetlands or aerobic treatment — to bring remaining parameters below discharge limits. Effluent after biogas still carries high nitrogen, phosphorus and micro-organisms, so “passed through biogas” does not mean “meets the discharge standard”. Farms must test the final effluent at the discharge point stated in the environmental permit, not sample mid-system and infer the final result.
For facilities with total wastewater below 5 m³ per day, QCVN 62-MT:2016/BTNMT sets tiered requirements instead of the concentration-limit formula: below 2 m³ per day, the facility must have a hygienic collection, sedimentation and decomposition system; from 2 m³ per day to below 5 m³ per day, it must have a collection and treatment system of sufficient capacity such as biogas or biological bedding conforming to national standards. For facilities of 5 m³ per day or more, the discharge concentration limit is calculated as Cmax = C × Kq × Kf, where C is the composition concentration in Table 1 of the Regulation, Kq is the receiving-water factor and Kf is the discharge-flow factor. If the discharge flow changes so that the applied Kf is no longer appropriate, the facility must report to the competent authority to adjust Kf. Expanding the herd and increasing discharge without reporting an adjustment is a form of operating outside the permit, even if measured effluent is temporarily below the standard.
5. Discharge standard QCVN 62-MT:2016/BTNMT: reading the limit table correctly
QCVN 62-MT:2016/BTNMT sets permissible concentration limits for components in livestock effluent discharged into receiving waters. Table 1 sets concentration C in two columns: Column A applies when treated effluent is discharged into a water body used for domestic water supply; Column B applies when it is discharged into a water body used for other purposes. The C values are:
- pH: Column A 6–9; Column B 5.5–9.
- BOD5: Column A 40 mg/l; Column B 100 mg/l.
- COD: Column A 100 mg/l; Column B 300 mg/l.
- Total suspended solids (TSS): Column A 50 mg/l; Column B 150 mg/l.
- Total nitrogen (N): Column A 50 mg/l; Column B 150 mg/l.
- Total coliform: Column A 3,000 MPN or CFU/100 ml; Column B 5,000 MPN or CFU/100 ml.
Three points matter when reading this table. First, for pH and total coliform, Cmax = C — no Kq or Kf multiplier applies. Second, for livestock effluent discharged into urban or residential drainage without a centralised wastewater treatment plant, Cmax = C under Column B. Third, effluent discharged into the collection system of a centralised wastewater treatment plant follows the rules of that plant’s management board, not Table 1 directly. A farm must establish which column applies and where it discharges before concluding it “meets the standard”: the same test result may exceed the standard for a domestic-supply source while passing for another purpose, and vice versa. Where the environmental permit states specific discharge limits for each source, those permit limits are the numbers the farm must meet every day; the Regulation is the basis on which the licensing authority sets them.
6. Gas, odour, dust and dead animals: the streams most often overlooked
Farm gas and odour have no single limit table like wastewater, but they are still operating obligations: sheds must be ventilated, manure and wastewater collected promptly, manure stores covered, and biogas and treatment systems sealed and run at design capacity. The most effective odour control is usually not spraying a product after odour has spread, but shortening the time manure sits in sheds, keeping shed floors dry, separating solid manure early, and maintaining biological bedding correctly. When neighbours complain about odour, authorities inspect operating procedures and safe distances, not just one air sample at one moment.
For dead animals, the rule is to deal with them immediately, never leave them standing and never discard them into the environment. Animals that died of disease must be handled under animal health and environmental protection rules (Clause 2, Article 59 of the Law on Animal Husbandry 2018), including reporting, isolating the area and disposing of carcasses as directed by the veterinary authority. Veterinary packaging, syringes and disinfectants are hazardous waste: collect separately, store separately, and hand over to a licensed treatment unit. Mixing them into compost or household rubbish violates both the sorting duty and the handover duty. Farms should keep a separate log for this stream: date, type, volume, receiving unit and handover record.
7. Periodic environmental monitoring: what to measure, how often, and who receives the report
Periodic environmental monitoring means measuring, sampling, analysing and evaluating environmental components and waste from a facility’s operation, to control waste generation and treatment, assess compliance with national technical regulations, and provide data for state environmental management. The legal basis is Articles 111 and 112 of the Law on Environmental Protection 2020 (wastewater monitoring; dust and exhaust-gas monitoring) and Articles 97 and 98 of Decree No. 08/2022/ND-CP, with detailed guidance in Circular No. 02/2022/TT-BTNMT. In practice, each farm’s monitoring programme sits in its environmental permit: which parameters to measure, where to sample, and how often. A farm must not shorten the programme in its permit, nor sample at a convenient point instead of the registered discharge point.
Under the framework of Decree No. 08/2022/ND-CP, periodic wastewater monitoring for continuously operating projects and facilities is every 3 months where an environmental impact assessment is required and every 6 months in other cases (Clause 3, Article 97 of Decree No. 08/2022/ND-CP); seasonally operating projects and facilities follow a separate framework, as set in the permit. For periodic dust and exhaust-gas monitoring, the framework depends on the parameter under Clause 4, Article 98 of Decree No. 08/2022/ND-CP: for continuously operating projects and facilities subject to environmental impact assessment, heavy metals and organic compounds every 6 months, dioxin/furan once a year, and the remaining parameters every 3 months; for continuously operating projects and facilities not subject to environmental impact assessment, heavy metals, organic compounds and dioxin/furan once a year, and the remaining parameters every 6 months; seasonally operating projects and facilities follow a separate framework as set in the permit; and the specific parameters and frequency still follow the farm’s environmental permit. Farms should therefore set a full-year monitoring calendar at the start of the year, contract a qualified monitoring unit, and retain all test reports, sampling records and contracts. If a monitoring result exceeds the permit limit, the farm must reduce or stop the non-compliant discharge, inspect the failing treatment stage, remedy it and re-test — not wait for the next monitoring round, and never conceal an exceedance. Alongside the regular measurement schedule, a farm is obliged to complete and file on time its reports on compliance and on environmental protection work with the licensing authority and the local environmental authority, and to preserve in full its monitoring documents together with its waste collection and treatment contracts so they can be produced when inspected.
8. When operations go wrong: two penalty frameworks that must stay separate
This is the easiest part to get wrong, and the point this article stresses most. Violations of animal husbandry conditions and livestock waste treatment — for example failing to treat waste as required, or failing to keep safe distances — fall under Decree No. 211/2026/ND-CP, with the group covering husbandry conditions and waste treatment carrying a range of 1–30 million VND plus remedial measures, under that Decree’s own convention that fines are set for individuals and doubled for organisations. By contrast, operating without an environmental permit where one is required, and discharging effluent above technical regulations, fall under the environmental protection penalty framework — Decree No. 45/2022/ND-CP — where fines scale with the exceedance level and discharge flow, with remedial measures, and in serious, repeated cases possible stripping of the right to use the environmental permit for a term or suspension of the polluting operation. This article deliberately does not attach any environmental-framework fine figure to Decree No. 211/2026, and does not use the 1–30 million VND range of Decree No. 211/2026 to infer the consequence of discharging above the standard. When reading any fine table, a farm should first check which decree it comes from.
In operational terms, when a treatment system fails, the correct sequence is: reduce load or stop the non-compliant discharge; inspect the failing stage (blockage, overload, weakened microbial culture, leak); remedy it and re-test at the discharge point; and record the whole incident and the measures taken in the operating log. That log is both evidence of good faith for inspectors and data showing which stage of the farm’s own system is weak. Before enlarging the herd, switching to a different treatment technology or moving the discharge point, a farm should first check the rules on amending and re-issuing the environmental permit to see whether the planned change falls within a case that requires that procedure; carrying out the change first and only then seeking an amendment puts the farm on the quickest path to a violation.
9. Daily, monthly and quarterly operating checklist
- Daily: collect manure and solid waste on schedule; check the biogas digester, settling tanks and collection channels; record discharge flow and operating status; deal immediately with dead animals and hazardous waste arising.
- Weekly: inspect composting areas, bedding, roofing and leachate channels; check contracts and collection schedules of external waste treatment providers.
- Monthly: compare waste volumes against design capacity; check whether treated products yet qualify for reuse; update the hazardous waste and dead-animal log.
- Quarterly or as the permit requires: carry out periodic monitoring with the permit’s parameters, locations and frequency; submit compliance reports; file test reports and sampling records.
- When anything changes: larger herd, new technology, new discharge point, permit nearing expiry — check the duty to adjust or renew the permit before changing operations.
Frequently asked questions
Does holding an environmental permit mean a farm may discharge freely?
No. An environmental permit only allows discharge within the limits it states: sources, flow, parameters and discharge limits. Discharging above the permit limit or above QCVN 62-MT:2016/BTNMT is still sanctioned under the environmental protection framework, even while the permit remains valid.
Can water that has passed through a biogas digester be discharged straight into a river?
Not necessarily. Post-biogas water still carries high nitrogen, phosphorus and micro-organisms and often does not meet discharge limits. The farm must treat it further after biogas and test the final effluent at the discharge point, against Column A or Column B of QCVN 62-MT:2016/BTNMT depending on the receiving water’s purpose, and against the limits in its environmental permit.
Can untreated manure be hauled away and spread on another field?
Not as direct use. Under Clause 2, Article 59 of the Law on Animal Husbandry 2018, organic solid waste must be treated to national technical regulations before use as fertiliser or aquaculture feed; untreated waste may only be moved out of the farm to a treatment site by dedicated equipment and vehicles.
How often is periodic environmental monitoring required?
As set in the farm’s own environmental permit programme. Under Decree No. 08/2022/ND-CP the framework for periodic wastewater monitoring of continuously operating projects and facilities is every 3 months where an environmental impact assessment is required and every 6 months in other cases; seasonally operating projects and facilities follow a separate framework, as set in the permit; the farm must apply exactly the frequency and parameters in its permit, without shortening them.
Are failing to treat waste and discharging above the standard penalised the same way?
No. Failing to treat waste as required falls in the husbandry-conditions and waste-treatment group under Decree No. 211/2026/ND-CP (1–30 million VND, the individual rate, doubled for organisations, plus remedial measures). Discharging above the standard and operating without a required environmental permit fall under the environmental protection framework in Decree No. 45/2022/ND-CP. The two frameworks must not be swapped.
