Reverse logistics — collecting defective goods, returns and post-consumer packaging — used to be treated as a clean-up cost. Since extended producer responsibility (EPR) took effect, it has become a legal obligation with recycling rates, yearly timelines and two compliance routes: organising recycling yourself or contributing financially to the Vietnam Environment Protection Fund. Producers, importers and retail chains must therefore redesign their reverse chain as a compliance system, not just an after-sales service.
Which products fall under EPR
Under Articles 54 and 55 of the Law on Environmental Protection 72/2020/QH14 and Decree 08/2022/ND-CP, recycling responsibility phases in for product and packaging groups: packaging, batteries and accumulators, lubricating oils, tyres, electrical and electronic products and vehicles, with mandatory recycling rates rising year by year for each group. Separately, a waste-treatment duty applies to products containing hazardous substances such as plant protection chemicals and single-use batteries. The duty attaches to producers and importers — meaning an electronics importer in Vietnam cannot push its reverse obligation onto the overseas factory.
The two compliance routes: recycle or contribute
An EPR-obligated business may organise collection and recycling meeting the prescribed rates — directly, through qualified recyclers, or jointly via a producer responsibility organisation (PRO) — or contribute financially to the Vietnam Environment Protection Fund at rates calculated on the volume of products and packaging placed on the market. Choosing the contribution does not remove reporting: the business must still register, declare volumes and report results as required. Many businesses pick a hybrid: self-collecting streams with high recycling value and contributing for dispersed, hard-to-collect streams.
When returns become hazardous waste in the chain
Most e-commerce returns go back on the shelf, but part of the flow becomes waste the moment it is graded: swollen lithium batteries in returned devices, expired cosmetics, leaking chemicals. From that point, reverse logistics must follow hazardous-waste rules on classification, storage, transport and handover to licensed handlers. A reverse-logistics contract must therefore fix the point where ownership and environmental responsibility for returned goods transfer — returned goods remain the seller’s property until a written disposal decision exists, and the carrier may not destroy them on its own initiative.
Designing a reverse-logistics contract around EPR
A compliance-grade reverse-logistics contract needs: definitions of return quality grades and an image-documented grading process; responsibility for collecting volume data per product group for the company’s EPR reporting; an unbroken handover document chain from collection point to recycling or treatment facility; a clause on non-recyclable items and hazardous-waste treatment costs; and the company’s audit rights over the logistics provider’s records. Today’s reverse-chain data is tomorrow’s EPR evidence file — without it, a business can neither prove its recycling rates nor defend itself against deemed volumes.
Frequently Asked Questions
Which products carry EPR recycling duties?
EPR under Articles 54 and 55 of the Law on Environmental Protection 72/2020 and Decree 08/2022/ND-CP phases in for packaging, batteries, lubricating oils, tyres, electrical and electronic products and vehicles, with recycling rates rising by year; a separate waste-treatment duty covers products with hazardous substances. The duty attaches to producers and importers in Vietnam.
Can an obligated company pay money instead of recycling?
Yes: it may organise recycling meeting the prescribed rates or contribute financially to the Vietnam Environment Protection Fund based on volumes placed on the market. The contribution does not remove the duties to register, declare volumes and report results as required.
Which returns count as hazardous waste in reverse logistics?
Returned items that are hazardous when graded for disposal: swollen lithium batteries, damaged accumulators, expired chemical-containing cosmetics and leaking chemicals. From that point, storage, transport and handover must follow hazardous-waste rules and go only to properly licensed handlers.
This article has been quality-reviewed by the FLAW AI Legal Council