Environmental Registration for Small-Scale Livestock Farms in Vietnam: Dossier, Commune-Level Filing and Deadlines

1. What environmental registration is, and how it differs from an environmental permit

Environmental registration is the procedure by which the owner of an investment project or a production, business or service establishment that generates waste but is not required to hold an environmental permit (EP) notifies the state within the time limit prescribed in Clause 6, Article 49 (see §6). The legal basis is Article 49 of the Law on Environmental Protection 2020 (Law No. 72/2020/QH14). The decisive difference is the nature of the procedure: applying for an EP means seeking approval — the competent authority appraises the dossier and issues a permit with specific discharge parameters and a validity period — whereas environmental registration is a filing: the receiving authority records it and updates the national environmental information system and database. The commune-level People’s Committee receives the registration; it does not issue a time-limited “permit” of the kind an EP represents.

Farm owners should therefore ask the right question. Not “how long until my registration is granted”, but “which category does my farm fall into, what dossier must I file, where do I file it, and by when”. Getting the category wrong — registering when an EP is actually required — leaves the farm operating without the permission it lacks, because a registration cannot substitute for a missing EP.

2. How a “small-scale” farm is measured

Farm scale is measured in livestock units. Decree No. 13/2020/ND-CP, guiding the Law on Animal Husbandry, provides: a large-scale farm has 300 livestock units or more; a medium-scale farm has from 30 to under 300; a small-scale farm has from 10 to under 30; and under 10 is household husbandry. One livestock unit (for livestock and poultry) equals 500 kg of live animal weight, regardless of species, age or sex. By way of illustration only, a finishing-pig farm holding 100 pigs at about 100 kg each holds roughly 20 livestock units and sits in the small-scale band — but owners must calculate on their own herd’s actual total live weight.

The most common mistake is equating “small-scale” with “registration only”. Farm scale is a husbandry-law classification; whether an EP or only registration is required is decided by environmental law, through project grouping under Article 28 of the Law on Environmental Protection 2020 and the criteria and lists in Appendix II to Decree No. 08/2022/ND-CP (as amended by Decree No. 05/2025/ND-CP). Small scale is therefore the starting point for identifying the farm, not the final answer on procedure. A small farm that falls within Article 39 of the Law on Environmental Protection 2020 must still obtain an EP; a small farm outside EP scope that generates waste files an environmental registration.

3. Three cases: EP required, registration only, exempt from registration

Every farm owner should place the farm in one of the following three cases, working from the heaviest obligation downwards:

• EP required: investment projects and establishments within Article 39 of the Law on Environmental Protection 2020 — group I, group II and group III projects that discharge wastewater, dust or emissions requiring treatment, or that generate hazardous waste requiring management under the regulations. These farms go through the EP procedure; registration is not a substitute.
• Registration only: investment projects and establishments that generate waste but are not required to hold an EP (Clause 1, Article 49 of the Law on Environmental Protection 2020). This is the typical case for a small farm: manure, husbandry wastewater, solid waste, odour and animal carcasses arise from daily raising, but their scale and character do not reach EP thresholds.
• Exempt from registration: the cases in Clause 2, Article 49 of the Law on Environmental Protection 2020 and Article 32 of Decree No. 08/2022/ND-CP, including projects and establishments involving state secrets on national defence and security; projects that on operation generate no waste or only a small volume of waste treated by on-spot treatment facilities or equipment or managed under local administration regulations; and the list in Appendix XVI to Decree No. 08/2022/ND-CP. Decree No. 08/2022/ND-CP quantifies “small volume” for the exemption: domestic solid waste under 300 kg per day managed under local regulations; or wastewater under 5 m³ per day; or emissions under 50 m³ per hour, treated by on-spot facilities or equipment or managed under local regulations.

Exemption from registration is not exemption from environmental duties. An exempt farm must still collect and treat its waste, must not discharge untreated waste into the environment, and must still meet husbandry conditions under the Law on Animal Husbandry 2018 on location, safety distances, housing, waste treatment and disease prevention. An owner claiming exemption should record the legal basis and keep supporting records, because an inspector will ask for the basis rather than accept a general assertion.

4. What the registration dossier contains

Under Article 22 of Circular No. 02/2022/TT-BTNMT, an environmental registration dossier has only two components: the owner’s environmental registration document made using Form No. 47 in Appendix II to the Circular; and a copy of the decision approving the appraisal results of the project’s environmental impact assessment report (if any). For a small farm the second component is usually absent, since the farm is not subject to environmental impact assessment; the dossier is then in practice a single registration document, but it must still declare the full contents.

The contents of a registration are set out in Clause 4, Article 49 of the Law on Environmental Protection 2020. Owners should prepare the following five groups of information in Form No. 47:

1. General information: the farm owner’s name (organisation, individual or household business), address, farm location, and herd size expressed in livestock units.
2. Activity type, technology, capacity and products: species raised, raising method (confined or semi-free-range), housing capacity and husbandry products; materials, fuels and chemicals used, if any (feed, veterinary medicines, disinfectants).
3. Types and volumes of waste generated: manure and husbandry wastewater, domestic solid waste, husbandry solid waste, animal carcasses, veterinary medicine packaging, and odour and housing emissions — declared as actually generated, not understated to stay below a threshold.
4. Waste collection, management and treatment plan: the manure collection system, biogas digester or wastewater treatment tank, solid waste storage area, collection contracts with licensed units where applicable, carcass handling, and odour control measures.
5. Environmental protection commitments: a commitment to carry out the registered plan, to comply with environmental technical regulations, and to bear legal responsibility for the accuracy of the registration.

The three most frequent dossier errors are: waste volumes that do not match herd size; treatment works that are not yet built being described as if already operating; and a missing carcass-handling plan — a waste stream specific to husbandry that the receiving authority always looks for. Registration is not appraised like an EP dossier, but a false declaration remains grounds for handling on inspection, because the owner is responsible for the truthfulness of the filing.

5. Where and how to file

There is one filing destination: the People’s Committee of the commune where the project or establishment is located. Clause 3, Article 49 of the Law on Environmental Protection 2020 and Articles 22 and 23 of Circular No. 02/2022/TT-BTNMT provide that owners file directly, by post or through the online public service system with the commune-level People’s Committee, which receives the dossier and updates the registration data in the national environmental information system and database. A farm spanning two or more commune-level administrative units may choose one commune-level People’s Committee for registration.

On the post-reform local government structure: from 1 July 2025, local government is organised in two tiers — the provincial tier and the grassroots tier — with no district tier; grassroots-level administrative units comprise communes, wards and special zones. “Commune level” in Article 49 therefore means in practice the People’s Committee of the commune, ward or special zone where the farm sits, depending on the actual locality. Owners should not file a registration with the province, and there is no longer a district-level committee to file with; filing with the wrong tier is filing with the wrong receiving authority under the law.

On filing method, the online public service system is preferable where the locality has deployed it, because the electronic dossier feeds directly into the environmental database; for direct or postal filing, owners should keep a copy of the registration document and proof of filing (receipt or postal tracking) as evidence that the obligation was performed.

6. Deadlines: when to file, how long processing takes, and whether registration expires

The registration deadline is prescribed in Clause 6, Article 49 of the Law on Environmental Protection 2020, in three branches: (a) projects subject to environmental impact assessment (EIA): register before official operation; (b) projects not subject to EIA: register before the competent authority grants a construction permit if a construction permit is required, or before discharging waste into the environment if no construction permit is required; (c) establishments already operating before the Law took effect (1 January 2022): register within 24 months from the date the Law took effect — that window closed on 1 January 2024. A farm already operating that has never registered should register immediately, since the 24-month period under Clause 6(c) closed on 1 January 2024. By way of example: a farm that requires a construction permit and finishes building its housing before registering is already late, because the correct deadline is before the construction permit is granted — that is, before construction itself.

On processing time: the law sets no appraisal or issuance deadline for environmental registration of the kind that applies to EPs, because registration is receipt and data updating, not licensing. Owners should therefore not wait for an “approval of registration” decision before raising animals; what matters is filing a complete and accurate dossier with the correct commune-level People’s Committee and keeping proof of filing. If the dossier lacks information required by Form No. 47, the commune-level People’s Committee may request supplementation, and owners should supplement promptly so that the data on the system matches actual operation.

On validity: the Law on Environmental Protection 2020 and Circular No. 02/2022/TT-BTNMT prescribe no validity period for environmental registration as they do for EPs. A registration remains valid while the registered contents still match reality. When a farm changes registered contents — herd expansion, a change of species, a change of waste treatment technology, or an increase in waste volumes — the owner must file a new registration reflecting the changed contents with the commune-level People’s Committee before the change takes effect. And if the change brings the farm within EP scope under Article 39, the owner must obtain an EP before implementing that change; the old registration will no longer suffice.

7. What continues after registration

Registration is not the end of environmental obligations. Owners must still operate in accordance with the registered waste collection, management and treatment plan; comply with environmental technical regulations on wastewater, emissions and solid waste; and submit reports on environmental protection work using Form No. 05.B in Appendix VI to Circular No. 02/2022/TT-BTNMT to the registration-receiving agency. Subjects exempt from registration under Article 32 of Decree No. 08/2022/ND-CP are not required to submit this report — one more distinction between “exempt from registration” and “registered”.

The commune-level People’s Committee that receives the registration is also the level of government closest to the farm and competent to inspect compliance with environmental protection law by the subjects whose registrations it receives in its locality. The practical consequence is straightforward: the closer the registration matches actual operation, the lower the inspection risk; a farm that registers one thing and operates another — for example registering biogas treatment while discharging directly into a ditch — is the easiest case for an inspection record.

8. Pre-filing checklist

1. Determine the correct category: check Article 39 before Article 49; if EP scope is possible, stop and pursue the EP procedure instead of filing a registration.
2. Calculate herd size in livestock units (1 unit = 500 kg live weight) and enter it correctly in Form No. 47.
3. List every waste stream of the farm, including animal carcasses and veterinary medicine packaging.
4. Describe a treatment plan matching works actually in place, not works not yet built.
5. Identify the correct commune-level People’s Committee for the farm’s location (commune, ward or special zone); for a farm spanning communes, choose one and record the choice.
6. File within the Clause 6, Article 49 deadline: before official operation for EIA projects; before the construction permit is granted for non-EIA projects requiring one; before discharging waste into the environment where no construction permit is required; keep the receipt or postal proof as evidence of filing.
7. Remember: any change of scale, species or treatment technology requires a fresh registration before the change takes effect; crossing into EP scope requires an EP.

Frequently asked questions