Extended Producer Responsibility

Overview

The concept of extended producer responsibility (EPR) for handling the end-of-life stage of products in Indonesia dates back to 2008, with the Solid Waste Management Law No.18/2008. Article 15 of the law stipulates producers are responsible for the management of packaging and/or products that are difficult to dispose of or non-biodegradable. Law No.81/2012 on the Management of Household Waste and Household-like Waste provides more details on how producers are obligated to reduce, reuse, and recycle waste.

To enforce producer commitment to reduce household waste, the Presidential Decree No. 97/2017 on National Policies and Strategies for the Management of Household Waste and Household-like Waste called for national and local governments to formulate waste reduction and treatment plans for 2017-2025, where EPR is proposed as one of the measures. Against this backdrop, and further reinforced by the Presidential Decree No.83/2018 on Marine Debris Handling, the Indonesian government established the legal framework for the implementation of EPR in the Regulation of the Minister of Environment and Forestry of Indonesia No.75/2019 on Waste Reduction Roadmap by Producers, which was enacted on 5 December, 2019.

Table 1. Summary of policies, plans, and regulations regarding EPR for packaging in Indonesia.

Obligated Producers

The regulation is imposed on producers, which are identified as business entities that produce, import, or sell products made of and products packaged using materials that are difficult or non-biodegradable. The sectors and sub-sectors of obligated producers are further specified into the following:

Packaging Items Covered

Obligated producers are required to reduce the waste of packaging and products made from plastics, aluminium cans, glass, and paper, which are non-biodegradable, non-recyclable, and/or non-reusable. The list of packaging items covered under the regulation is detailed in Table 2 below. 

Table 2. List of packaging items covered under Indonesia’s EPR scheme.

Mechanism of Implementation

Implementation Mechanism

The Waste Reduction Roadmap is scheduled for implementation from 2020 to 2029, during which producers are required to undertake the steps outlined below.

1. Planning: Submitting a strategic plan for waste reduction, which comprises information on the baseline of current waste generation, targets and timelines for waste reduction, targeted products, and measures taken to implement waste reduction. 

2. Implementation: Achieving waste reduction targets through activities stated in the submitted strategic plan.

3. Monitoring: Monitoring the type and number of products and packaging produced and/or used and reduced, as well as the measures implemented to achieve this. The monitoring shall be conducted on a bi-annual basis at the very least.

4. Evaluation: Comparing waste reduction targets and achievements during the period and identifying implementation challenges.

5. Reporting: Submitting a report including the type and number of raw materials reduced, biodegradable packaging produced, and reusable and/or recyclable raw materials used, as well as evaluation of the implementation of the waste reduction plan.

Producers must submit two document types: a strategic plan for waste reduction, and annual implementation reports.

Measures taken by producers in reducing waste align with the 3R (reduce, reuse, recycle) approach as mandated by Article 6 of the regulation.

Table 3. Approaches and measures to be included in producer’s 3R plan for products and packaging.

The implementation of waste recycling and reuse must be complemented by take-back or collection schemes, along with the provision of storage facilities. These facilities may take the form of cooperations with waste banks, Waste Processing Sites - Reduce, Reuse, Recycle also known as “Tempat Pengolahan Sampah Reduce, Reuse, Recycle” (TPS3R), or recycling centres. In addition to this, waste recycling and reuse can only be regarded as successful when producers collect their own product packaging. 

The regulation mentions that producers may assign a third party to conduct these activities in Article 16 but provides no explanation on the institutionalization of a Producer Responsibility Organization (PRO).

Implementation Timeline

In executing the roadmap, producers are expected to develop the plan for waste reduction during the period of 2020 to 2022, followed by the cyclical process of implementation, monitoring, evaluation, and reporting from 2023 to 2029.

Targets

The regulation targets producers reduce the waste generated from their own products by 30% by 2029. The target amount of waste to be reduced is calculated based on the baseline amount of waste generated as stated in the plan. By the end of 2029, numerous single-use plastic items are set to be phased out, including Styrofoam for food packaging, plastic cutlery, plastic straws, plastic shopping bags, and small-sized packaging.

Incentives and Penalties

To encourage greater producer participation, the law outlines incentives and awards. Producers may also receive public scrutiny for any failures in abiding by the regulation.

Roles and Responsibilities

Table 4. Roles and responsibilities under Indonesia’s EPR scheme for packaging.

*This is based on the regulation, not on the current waste management system in Indonesia.

Updated as of 21 March 2024.

Overview

Japan introduced the Act on the Promotion of Effective Utilization of Resources, which initiated EPR implementation by imposing on manufacturers the adoption of 3Rs (reduce, reuse, recycle). The legislation encouraged producers to voluntarily collect and recycle their products by specifying items for recycling and set recycling targets, along with outlining implementation methods. 

The transition from voluntary to compulsory EPR policy came with the Act on the Promotion of Sorted Collection and Recycling of Container and Packaging (Container and Packaging Recycling Act) in 1995. This law, effective two years after its promulgation, required producers of glass bottles and PET bottles, excluding small and medium-sized enterprises (SMEs), to recycle their post-consumer waste. The mandate expanded through an amendment in 2000 to include producers of paper and plastic containers and packaging.

Japan enacted the Basic Act on Establishing a Sound Material-Cycle Society, in the same year, setting the fundamental framework for shifting from a linear society to one promoting resource circulation. The law organises priority for waste disposal methods, emphasising reducing, reusing, recycling, heat recovery, and proper disposal. EPR is underscored as a fundamental principle in waste treatment, highlighting the shared responsibility between the national government, municipalities, businesses, and consumers in achieving the sustainable consumption of resources.

Table 1. Summary of policies, plans, and regulations regarding EPR for containers and packaging in Japan.

Obligated Producers

Under the Container and Packaging Recycling Act, businesses that use, manufacture, or import the designated packaging and meet the following conditions are subject to recycling obligations.

Table 2. The scope of businesses subject to EPR obligations in Japan.

Packaging Items Covered

The EPR policy requires producers to recycle different types of domestic waste, particularly the following materials.

Mechanism of Implementation

Implementation Mechanism

Responsibility sharing among stakeholders across the value chain is one of the prominent features of Japan’s EPR policy. Specifically for containers and packaging, the roles are distributed as follows:

1. Consumers are responsible for reducing waste discharge and properly sorting waste for disposal

2. Municipalities are in charge of collecting sorted waste

3. Businesses are responsible for recycling.

Obligated businesses may fulfil recycling obligations through one of the following three routes. 

1. Self-collection: Directly collecting packaging waste from consumers for recycling, typically used for items such as refillable bottles and polystyrene, often through supermarket collection stations.

2. Designated organisation: Outsourcing recycling responsibilities to a producer responsibility organisation (PRO) – the Japan Containers and Packaging Recycling Association (JCPRA) – which recycles sorted packaging waste collected by municipalities. Producers are required to pay a recycling commission to recyclers and contributory commission to municipalities through the JCPRA. This is the most commonly used route.

3. Own recycling: Allows businesses to recycle the collected packaging waste from municipalities either independently or through an organisation other than the PRO, although this route has never been utilised.

Designated business categories using large packaging volumes must report their reduction of packaging waste activities to the national government. If these are deemed insufficient, the government can issue recommendations or directives.

Implementation Timeline

The annual implementation schedule of Japan’s EPR system is outlined in the table below. It should be noted PRO refers to the JCPRA.

Table 3. Implementation timeline of Japan’s EPR scheme for containers and packaging.

Targets

The targeted packaging recycling amount for designated producers is determined based on the Municipal Sorted Collection Plans, which municipalities update every five years. Companies calculate their packaging waste proportion in relation to the total packaging waste collected by the municipality to arrive at their obligatory recycling amount. However, if the recyclers’ recycling capacity is below the amount of collected waste, the obligatory recycling amount is calculated by multiplying the recycling capacity by the company’s packaging waste proportion.

To fulfil these targets, the PRO designates the minimum yield for each recycling method which recyclers must adhere to. Business associations must also set voluntary collection and/or recycling targets for each item. 

Incentives and Penalties

Designated producers who fail to fulfil their recycling or packaging waste reduction obligations face penalties as outlined in the table below.

Table 4. Penalties imposed on producers who fail to meet their recycling and reduction obligations.

Roles and Responsibilities

Table 5. Roles and Responsibilities under Japan’s EPR scheme for containers and packaging

Overview

The impetus to establish sustainable resource circulation in the Republic of Korea led to the enactment of the Act on the Promotion of Saving and Recycling of Resources, known as the Recycling Act, in 1992. The law introduced the Deposit-Refund System (DRS), emphasising producer responsibility in promoting resource efficiency. Producers are mandated to place a deposit equivalent to the recycling cost of their items, which will then be refunded based on the volume of materials they recycle in that particular year.

A comprehensive amendment to the Recycling Act rreplaced the Deposit-Refund Scheme with an extended producer responsibility (EPR) system in 2002. The government aimed to enhance producer engagement in managing their products’ waste by enforcing mandatory recycling measures, rather than offering economic incentives for compliance. While producers bear the legal obligations of recycling waste, the Korean EPR system requires responsibility sharing among stakeholders, including governments and consumers.

The Recycling Act of 2002 laid the groundwork for Korea’s current EPR system, targeting packaging materials and products including lubricants, batteries, and tyres. The Fundamental Act of Resource Circulation was promulgated in 2016 in a further commitment to sustainable resource circulation. The legislation underscores Korea’s commitment to reducing waste, promoting high-quality material recycling, and minimising reliance on incineration and landfilling.

Table 1. Summary of policies, plans, and regulations regarding EPR for packaging in the Republic of Korea.

Obligated Producers

Korea’s EPR system for packaging applies to producers who meet both the criteria based on annual sales and annual production or import weight in the preceding year, as outlined in the table below.

Table 2. The scope of producers and importers subject to EPR obligations for packaging in Korea.

Packaging Items Covered

Packaging items regulated under Korea’s EPR system encompass packaging for products including food and beverages, agricultural/fishery/livestock products, detergents, cosmetics, medicinal products and quasi-drugs made of the following materials.

Mechanism of Implementation

Implementation Mechanism

The implementation of the EPR system in Korea is overseen by the Korea Environment Corporation (KECO), a state-owned enterprise authorised by the Ministry of Environment (MoE) to execute its policies. For EPR for packaging, KECO is tasked with recording production or import data from producers, establishing guidelines for the recycling processes, and monitoring and verifying producers' recycling performance.

In fulfilling their recovery and recycling obligations, producers and importers have the option to establish individual EPR schemes or collectively join a producer responsibility organisation (PRO) – a choice favoured by most producers. The designated PRO for packaging is the Korea Packaging Recycling Cooperative (KPRC), responsible for collecting recycling fees and gathering information and statistics on the production, import, and recycling of packaging materials from its members. However, the KPRC is not directly involved in managing collection and packaging; this responsibility falls to the Korea Resource Circulation Service Agency (KORA).

KORA, a state organisation under the MoE, facilitates waste collection and recycling by coordinating with local governments, waste management organisations (WMOs), and recyclers. Household waste is collected by local governments, while WMOs, selected through public tenders, handle industrial waste collection. KORA uses the recycling fees collected by the PRO to finance waste collection and distribute funds to local governments and WMOs. KORA also issues service provision agreements with recyclers, assigning them tasks related to recycling and marketing recyclates. 

KECO conducts quarterly on-site verification of producer performance in collecting and recycling plastic packaging based on reported information. KECO then submits a report on producer compliance with EPR obligations to the MoE. The Korean EPR system for packaging is depicted below.

Implementation Timeline

The annual implementation schedule of Korea’s EPR system is shown in the table below.

Table 3. Implementation timeline of Korea’s EPR scheme for packaging.

Targets

The MoE annually announces the mandatory recycling rate for each item, taking into account factors such as recycling market conditions, collection and recycling capacity, and economic circumstances. The graph below illustrates the mandatory recycling rates for select packaging items from 2008-2024, presented on a four-year basis.

Incentives and Penalties

Producers falling short of meeting their recycling obligations face recycling charges, which are calculated as the recycling cost for the unmet portion plus a 30% surcharge. The government annually issues notifications regarding payment obligations on 31 July, with payments due by 31 August in the same year.

Roles and Responsibilities

Table 4. Roles and responsibilities under Korea’s EPR scheme.

Updated as of 21 March 2024.

Overview

The legal basis for waste management in the Philippines is institutionalized in the Republic Act No. 9003 (R.A. 9003), referred to as the Ecological Solid Waste Management Act of 2000. The national law governs the implementation of a systematic, comprehensive, and ecological solid waste management plan down to the district or barangay level1. R.A. 9003 lays the groundwork for the introduction of an Extended Producer Responsibility (EPR) policy by establishing a supportive enabling environment. 

In response to increasing concerns over the marine plastic debris issue in the country, the Department of Environment and Natural Resources (DENR) launched the National Plan of Action on Marine Litter (NPOA-ML) in 2021. The Action plan lays out a set of strategies to achieve a “Zero Waste to Philippine Waters by 2040”, with the development and implementation of an EPR system identified as one of these crucial strategies.  

Against this backdrop, the Government of the Philippines amended R.A. 9003 by providing further guidelines on adopting a mandatory EPR system through the enactment of the Republic Act No. 11898 or the EPR Act of 2022.

Table 1. Summary of policies, plans, and regulations regarding EPR for packaging in the Philippines.

Obligated Producers

Producers with the obligation to comply with the Act include the following categories.

1. Large Enterprises

   This category encompasses producers whose total assets exceed that of medium enterprises stated under Republic Act No. 9501 or the Magna Carta for Micro, Small and Medium Enterprises (MSMEs) (₱100 million). It includes brand owners who sell any commodity under a brand, product manufacturers that either directly or indirectly produce products under their brands, and importers of consumer goods intended to be sold, whether in original packaging or to be repackaged for distribution, to the general public.

2. Micro, Small and Medium Enterprises (MSMEs)

   Some MSMEs are also obliged to implement EPR when the total value of assets of all enterprises carrying the same brand exceeds that of medium enterprises (₱100 million).

3. Other

   Other persons and entities, as may be determined by the DENR Secretary.

Packaging Items Covered

The EPR Act 2022 regulates the mandate for obliged enterprises to manage plastic packaging waste specified below:

Mechanism of Implementation

Implementation Mechanism

Under the Act, Obliged Enterprises (OEs) are required to prepare and register an EPR Program with the National Solid Waste Management Commission (NSWMC). The program components include specific types of materials used, volume or weight of plastic packaging introduced into the market and their respective targets for recovery, reuse, and recycling. Implementation of the EPR Program may be conducted individually or collectively, with or without a Producer Responsibility Organisation (PRO).

The table below outlines the activities and strategies that may be encompassed within the EPR Program.

Table 2. Activities and strategies included in an Obliged Enterprise's EPR Program.

Beyond the defined set of activities, the OE's EPR Program should also entail a plan for expanding its coverage to encompass as much of the country as possible. This initiative is known as the Geographic Implementation Program or Roll-out plan.

Enterprises with a complete EPR programme submission are then ordered to pay the EPR Registration Fees and Annual Compliance Monitoring Fees, which will be accumulated into the EPR Special Fund, and start implementation. Based on ongoing analysis of data from the Philippine Statistics Authority, there are 2,130 enterprises that are considered plastic-producing industries that would be covered by the EPR Act. This number will further be evaluated based on analysis of assets data from the Security and Exchange Commission. As of May 2024, 917 EPR Programs have been submitted by OEs, collectives, and PROs.

In the year following the implementation period, obliged enterprises need to submit an audited report on their compliance performance with the Act, referred to as the EPR Compliance Audit Report (ECAR). This report must be certified by an independent third-party auditor before being submitted by July 15th every year, starting from 2024.

Implementation Timeline

Table 3. Implementation timeline of the Philippines’s EPR scheme.

Targets

The targeted recovery rate (relative to the OE's plastic product footprint from the previous year) at the end of each implementation year is, as follows:

Incentives and Penalties

The Government of the Philippines provides incentives for companies to comply with the Act in the forms of:

1. rewards and recognitions, in the form of monetary, which will be sourced from the EPR Special funds, or otherwise;

2. an incentive scheme to develop effective solid waste management, including recovery and diversion;

3. tax incentives;

4. EPR expenses are deductible from annual gross income; and

5. tax and duty exemption of donations, legacies, and gift.

In the event of a failure to register an EPR Program or meet the plastic recovery rate targets, the DENR has the authority to impose fines on obliged enterprises. These collected fines will be deposited into the EPR Special Fund. The specified amounts for these fines are outlined in the table below.

Table 4. List of penalties imposed on producers who fail to comply with the Philippines’s EPR scheme for packaging.

Roles and Responsibilities

Table 5. Roles and responsibilities under the Philippines’s EPR scheme for packaging.

*This is based on the regulation, not on the current waste management system in the Philippines.

Updated as of 10 January 2025.

Overview

Singapore began involving producers in efforts to reduce packaging waste in 2007, through the signing of the Singapore Packaging Agreement (SPA) between the National Environment Agency (NEA), industry actors, and non-governmental organisations. Under the voluntary agreement, companies pledged to improve their packaging designs and practices across the supply chain. 

In 2015, the Singapore government set the target of becoming a zero waste nation through the launch of the Sustainable Singapore Blueprint, with the aim of increasing the national recycling rate to 70% by 2030. This target encompassed a 30% domestic waste recycling, and 81% non-domestic waste recycling rate. 

Singapore then established the Zero Waste Masterplan in 2019 to further assist the transition from a 'take, make, waste' economy to a circular economy. The masterplan aims to expand the lifespan of Singapore’s only landfill, Semakau Landfill, by reducing the amount of waste sent there and increasing the overall recycling rate. The introduction of an EPR system was one of the measures laid out to increase the rate of recycling packaging waste.

The Resource Sustainability Act 2019 was the culmination of Singapore's EPR legal framework, and came into force on 4 October 2019. Part 4 of the Act governs the implementation of the Mandatory Packaging Reporting (MPR) Framework, laying the foundations for an EPR framework for managing packaging waste. Singapore formed the first phase of EPR implementation with the Beverage Container Return Scheme, through an amendment bill to the Act in 2023. This scheme is set to commence in 2025.

Table 1. Summary of policies, plans, and regulations regarding EPR for packaging in Singapore.

Mandatory Packaging Reporting

Obligated producers are required to submit information on the packaging they produce or import into Singapore each year under the framework of the MPR Scheme, accompanied by a 3R (reduce, reuse, recycle) plan to reduce packaging. This scheme serves a dual purpose: promoting the benefits, and motivating companies to reduce packaging usage. The comprehensive packaging data collected will play a crucial role in shaping future policies and programmes on the efficient management of packaging waste, including through EPR.

Obligated Producers (Mandatory Packaging Reporting)

Companies mandated to comply with the EPR scheme are producers supplying regulated goods in Singapore who:

1. Import regulated goods with specified packaging

2. Use specified packaging for the regulated goods (including the retailer)

3.  Have an annual turnover exceeding S$10 million.

Regulated goods include all items except those specifically prescribed as excluded (ie arms and explosives, machines, equipment, appliances, or other devices designed solely for industrial or manufacturing usage and any spare parts, lifts or escalators, sports or recreation equipment, aircrafts, spacecrafts, vessels, and motor vehicles).

Packaging Items Covered (Mandatory Packaging Reporting)

Packaging items to be reported include all types of packaging, either composed of a mono-material or a combination of materials. Packaging used for business-to-business (B2B) and business-to-consumer (B2C) are also covered by the MPR scheme. However, exceptions apply to:

Mechanism of Implementation (Mandatory Packaging Reporting)

Implementation Mechanism

Compliance with the scheme is performed through the actions outlined below. 

1. Registration: Obligated companies need to register in the Waste and Resource Management System (WRMS) MPR portal.

2. Submission of annual reports: For every year in which the company meets the criteria, it has to submit a report on the specified packaging imported or used during the entire year, complemented with the methodology used in recording the material, weight, and form of specified packaging.

3. Submission of a 3R plan for packaging: Companies are required to formulate and submit 3R plans for their packaging, with a three-year implementation timeline from the submission year. The 3R plan is based on any of the following plans: 

   1. Packaging reduction

   2. Collection for reuse

   3. Collection for recycling

   4. Consumer outreach

   5. Industry outreach

   6. Use of recycled content in packaging material

   7. Improving recyclability of packaging.

Implementation Timeline

The diagram below illustrates the implementation timeline of Singapore’s MPR Scheme.

Targets

There are no targets set in the MPR Scheme.

Incentives and Penalties

Companies which fail to submit a specified packaging report, submit a 3R plan, provide incomplete or inaccurate submissions as per the agency's direction, or keep inadequate records, are subject to the following penalties.

Table 2. List of penalties imposed on producers who fail to comply with the MPR Scheme.

Beverage Container Return Scheme

The beverage container return scheme represents the first phase of an EPR strategy for packaging waste in Singapore, building upon the MPR Scheme. Set to launch in 2025, the scheme has undergone public consultation since September 2022 and passed into law in the Resource Sustainability (Amendment) Bill 2023 Part 4B. Although it is still in development, some information on the scheme has been disclosed. 

Obligated Producers (Beverage Container Return Scheme)

The beverage container return scheme is mandatory for all producers of pre-packaged beverages who supply beverages in Singapore.

Packaging Items Covered (Beverage Container Return Scheme)

The scheme aims to increase the recycling rate and reduce the amount of waste of all pre-packaged beverages, both in plastic bottles and metal cans, with sizes ranging from 150 millilitres to 3 litres.

Mechanism of Implementation

Implementation Mechanism

The beverage container return scheme will be implemented by applying a refundable deposit of 10 cents on all pre-packaged beverages in Singapore, together with existing recycling initiatives such as the National Recycling Programme. The deposit will be circulated from beverage producers, scheme operators, designated return points, consumers, retailers, and then back to the producers. 

Implementation starts with beverage producers registering with a licenced scheme operator. Each beverage product supplied by the producers needs to be affixed with a deposit mark and listed to the scheme operator, forming the basis for calculating the deposit provided by producers. 

Upon purchase, consumers pay the 10 cents deposit, which will be refunded upon returning the container waste to designated return points. Most of these return points will be located in large supermarkets which serve as the major sales channels of pre-packaged beverages. 

Scheme operators, on behalf of producers, collect the empty beverage containers and transfer them to recyclers for recycling then circulated back into the value chain. The financial cost of this process (collection and recycling) is borne by producers, while any profits made by recyclers (material revenue) are paid back to the scheme operator.

Implementation Timeline

The implementation timeline for Singapore’s beverage container return scheme is not yet defined, but is expected to commence in 2025.

Targets

There are no targets defined under the beverage container return scheme.

Incentives and Penalties

Fines are levied on beverage producers who fail to adhere to the scheme, as a component of law enforcement. The table below outlines the penalties imposed for each offence.

Table 3. List of penalties imposed on producers who fail to comply with Singapore’s Beverage Container Return Scheme.

Roles and Responsibilities

Table 4. Roles and Responsibilities under Singapore’s Beverage Container Return Scheme.

Overview

The incorporation of Extended Producer Responsibility (EPR) regulations in Viet Nam’s legal framework began in 2005 with the enactment of the Law on Environmental Protection 2005 (No. 52/2005/QH11). Article 67 of the law required producers to recover and dispose of expired or discarded products, including packages that were hard to decompose in nature. This initiative was driven by the need to address pollution leaked from informal recycling activities in craft villages. Although this provision was later repealed by the Law on Environmental Protection of 2014 (Law No. 55/2014/QH13), the responsibility of producers for post-consumer waste continued to be emphasized.

In parallel, the Vietnamese Government strengthened its pursuit towards enhanced municipal waste collection and recycling as well as reduced rate of plastics bags use in 2009 through the enactment of National Strategy for Integrated SWM to 2025, vision to 2050. The following year, the Law on Environmental Protection Tax 2010 imposed tax on taxable plastic bags, comprising of high-density and linear low-density polyethylene resin (HDPE and LDPE).

Clarification on the responsibility of manufacturers under the EPR principle was then provided in the Prime Minister’s Decision No 16/2015/QD-TTg on Collection and Treatment of Discarded Products. Nevertheless, a shortfall in recycling capacity of the formal sector in replacing the informal sector limited implementation results. Furthermore, a lack of detailed regulations, guidelines, and sanctions hindered law enforcement.

In an effort to resolve this issue, the Vietnamese Government devised the National Action Program for Sustainable Production and Consumption for 2021-2030 in 2020 which outlines prioritized activities in support of EPR implementation, such as the promotion of reuse- and recycle-oriented product design. Additionally, the government enacted the Law on Environmental Protection 2020 (No. 72/2020/QH14), making fundamental adjustment to the EPR policy through the introduction of two articles which govern the responsibilities of producers and importers for recycling products and packaging (Article 54) and waste treatment (Article 55). Detailed rules and guidance are provided in the Decree No. 08/2022/ND-CP on elaboration of several Articles of the Law on Environmental Protection (hereby referred to as the Decree) and the Circular No. 02/2022/TT-BTNMT on Implementation Rules for a Number of Articles of the Law on Environmental Protection, both enacted in 2022. Sanctions for failing to implement EPR are also regulated in (Article 32 and Article 33) of Decree No. 45/2022/ND-CP on Regulations on sanctioning administrative violations in the field of environmental protection.

The Minister of Natural Resources and Environment (MoNRE) issued Decision No. 252/QD-BTNMT on February 14, 2023, establishing the National EPR Council, an intersectoral coordinating organization whose main task is to assist the Minister of MoNRE in managing, supervising, and supporting the implementation of the recycling responsibilities of products and packaging, as well as the collection and treatment of waste by producers and importers as prescribed by law. The National EPR Council established and is operating the National EPR Portal, and integrating with data of tax, customs, business registration and such other related databases to have reporting and declaration by the manufacturers or importers in line with the regulations. Further details on the current regulation on EPR in Viet Nam are elaborated below.

Table 1. Summary of policies, plans, and regulations regarding EPR for packaging in Viet Nam.

Obligated Producers

Viet Nam adopts a hybrid-EPR model which assigns different responsibilities to producers across various sectors, encompassing treatment responsibility and recycling responsibility. 

Regardless of the type of responsibility assigned, organizations and individuals who manufacture or import recyclable products and packaging are obliged to comply with the EPR scheme delineated under the Law on Environmental Protection 2020 if they meet the following criteria:

1. packaging producers, with a revenue surpassing 30 billion VND in the preceding year, and

2. importers, with a revenue surpassing 20 billion VND in the preceding year.

Packaging Items Covered

The recycling responsibility extends to six categories of products: packaging, batteries and cells, lubricating oils, tires and tubes, electrical and electronic equipment (WEEs), and vehicles. The packaging prescribed under this scheme include consumer packaging for:

1. food

2. cosmetics

3. medicine

4. fertilizers, feeds, and veterinary drugs

5. detergents, and

6. cement.

The types of packaging specified in Annex XXII of the Decree are as follows:

On the other hand, the products and packaging subject to producers’ treatment responsibility as specified in Annex XXIII of the Decree include:

1. agrochemical packaging (plastic bottles and boxes, plastic bags and packages, glass bottles and jars, mettle bottles, jars and boxes);

2. disposable batteries;

3. chewing gums;

4. disposable napkins, diapers, tampons and wet wipes;

5. cigarettes; and

6. products with synthetic resins, including

   1. disposable trays, bowls, chopsticks, glasses, cups, knives, scissors, chopsticks, spoons, forks, straws, stirrers, containers and food wraps;

   2. balloons, duct tapes, ear buds, toothpicks, disposable toothbrushes, disposable toothpastes, disposable shampoo and conditioner, disposable razors;

   3. clothes of all kinds and accessories;

   4. leather goods, bags, shoes and sandals of all kinds;

   5. toys of all kinds;

   6. furniture of all kinds;

   7. building materials of all kinds; and

   8. non-biodegradable plastic bags with dimensions less than 50 cm x 50 cm and a wall thickness of less than 50 µm.

Mechanism of Implementation

Implementation Mechanism

There are two approaches of which producers may select to fulfill their recycling responsibility, as elaborated below.

1. Organize recycling

   This involves recycling the product or packaging waste independently, hiring a recycling service provider, fully delegating a third party such as a Producer Responsibility Organization (PRO), or a combination of these methods. Producers may choose one of the selected recycling solutions for every product category as provided in the Decree. After selecting a method, producers must register their recycling plan with the Ministry of Natural Resources and Environment (MONRE). Additionally, they are required to report their annual recycling results to MONRE. Also, the list of approved products and packaging recycling organizations is continuously updated and announced by MoNRE to support implementation.

2. Making financial contribution 

   Alternatively, producers have the option to make financial contributions to the Viet Nam Environmental Protection (VEP) fund. The amount is calculated using a specific equation that considers different standard recycling costs (Fs) for various types of products and packaging. The collected fund will be directed to support agencies and organizations working on the segregation, transport, recycling, and treatment of the products and packaging covered under the EPR system. Currently, the regulation on the management and use of financial contributions to the Viet Nam Environmental Protection Fund to support the recycling and waste treatment of producers and importers are being drafted by the MoNRE and the EPR Council and will be issued in the near future.

The obligatory amount for recycling is determined by the quantity of products and packaging introduced to the market or imported in the previous year, along with the mandatory recycling rate applied to each product category. Should producers surpass the prescribed recycling rate, any surplus in recycled products can be carried forward to the subsequent year.

In the case of fulfilling waste treatment responsibility, producers are obligated to make financial contributions to the VEP fund (VEPF). The summary of the mechanism of implementation for each responsibility under Viet Nam’s EPR scheme is provided in Table 2.

Table 2. Mechanism of implementation of Viet Nam’s hybrid-EPR model

(Source: e-Policy Consulting Limited Ltd., 2024)

Implementation Timeline

The scheduled implementation date for each product categories is outlined as follows:

The annual implementation schedule of the EPR system is elaborated in the table class="table table-striped" below.

Table 3. Annual implementation schedule of Viet Nam’s EPR scheme.

Targets

For the initial three years of EPR implementation for the recycling responsibility, producers are required to meet the mandatory recycling rates, which are adjusted for different product categories as presented in Annex XXII of the Decree. The recycling rates for packaging are set between 10-22%. These recycling rates will undergo incremental increases every three years, with adjustments kept to less than 5%.

Incentives and Penalties

Producers that fail to comply with the law are imposed with the following penalties

• fines up to 1 billion vnd for individuals, and 2 billion vnd for legal entities; Fines for violations in implementing EPR, including responsibility for recycling and in treatment for products as well as packaging by producers and importers range from 50 million to 1 billion VND;

• compulsory contract termination;

• removal from the recycling organizations, units, and authorized recycling entities list; and

• violation information publication.

Roles and Responsibilities

Table 3. Roles and Responsibilities under Viet Nam’s EPR scheme.

*This is based on the regulation, not on the current waste management system in Viet Nam.

Updated as of 15 January 2025.

Overview

Germany grappled with a surge in packaging consumption in the late 1980s, driven by economic growth exacerbating the strain on waste management facilities. Insufficient infrastructure, including landfills, incinerator plants, and composting facilities, could not accommodate the escalating packaging waste from private households and small-scale businesses.

In response, the German government introduced the Packaging Waste Ordinance (VerpackV) in 1991, pioneering closed cycle economy principles and product responsibility. This landmark ordinance targeted closing the materials loop and reducing disposed packaging waste by integrating disposal costs into product sales prices. 

The ordinance underwent revisions over the years, notably in the late 1990s when extended producer responsibility (EPR) principles for packaging were introduced. Manufacturers and distributors were tasked with return and disposal obligations, inaugurating the Dual System – a nationwide collection and recycling system of used sales packaging. The system enabled producers to fulfil their take-back and recycling duties through delegation to third party operators. 

However, challenges emerged, including inadequate participation from all obligated producers, giving rise to free riders. To ensure fair participation, the German government replaced the Packaging Waste Ordinance with the Packaging Act (VerpackG) in 2019. The Act introduced universal registration requirements with the Central Agency before placing packaging with mandatory system participation on the market. This update aimed to level the playing field and enhance the effectiveness of packaging waste management. Further details on the Act are below.

Table 1. Summary of regulations regarding EPR for packaging in Germany.

Obligated Producers

The Packaging Act imposes a registration obligation to anyone in Germany who produces, imports or additionally packages goods for private end customers, such as online retailers. There is no limit on small companies for this obligation.

The Act also imposes the obligation to file a declaration of completeness. Unlike registration, this obligation applies to selected producers who meet the criteria outlined in Table 2.

Table 2. The scope of businesses subject to the obligation of filing a declaration of completeness under Germany’s EPR scheme.

Packaging Items Covered Under EPR

Companies are under obligation when they use any packaging that typically ends up in a private consumer’s trash after use, including the packaging categories outlined below.

Mechanism of Implementation

Implementation Mechanism

To comply with the Packaging Act, producers are required to undertake the following steps.

1. Registration: Obligated producers are required to register in the LUCID public register, part of the Central Registry Packaging Regulation (Central Registry), and licence their packaging with a nationwide take-back system for used sales packaging (system operator) before circulating their products. Registration entails providing the following information: 

   • Complete company and contract details

   • National identity number including the European or national tax registration number of the manufacturer

   • Brand names under which the manufacturer sells packaging that has to participate in a take-back system

   • Declaration that the legal obligation to contract with a take-back system has been fulfilled, declaration that all data given by the manufacturer is true.

   The names of registered producers are made publicly available on the Central Agency’s website, ensuring complete transparency for all market players. Around 975,000 producers had registered in the LUCID packaging register as of March 2024.

2. System Participation: Producers must finance the recovery and recycling of their packaging by participating in one or more dual systems with a system operator to ensure nationwide take-back. System operator roles include:

   • Recovering packaging waste disposed by private final consumers in yellow bags/bins, paper bins and paper/glass containers and recycling them

   • Ensuring packaging waste is collected, sorted and recycled across Germany, and recycling quality is as high as possible.

3. Reporting: Producers must report the packaging data registered with the take-back system to the Central Registry without delay, including the following attributes:

   • Registration number 

   • Material category and quantity of the packaging registered 

   • Name of the take-back system in which the packaging participates

   • Period of participation in the take-back system.

This report can be prepared by a third party, but must be submitted first hand by the producer. Unlike in the case of the declaration of completeness, this reporting requirement is not subject to a de minimis threshold. This means that even those placing small quantities on the market must submit their data to the Central Agency, as specified above. 

Declaration of Completeness: Producers subject to the related obligation must submit a declaration of completeness reviewed by registered experts, auditors, tax consultants or chartered accountants. Producers must also disclose deductions because of damaged or unsaleable packaged goods and the fulfilment of recycling requirements confirmed separately.

The elaborated steps are summarized in Figure 1.

Implementation timeline

The initial registration obligation took effect immediately upon the enactment of the Packaging Act on 1 January, 2019. Once registered, producers have to regularly submit data reports regarding the take-back system. The declaration of completeness for the previous year must also be submitted annually by 15 May.

Targets

The Packaging Act sets recycling targets producers must meet every year, with details outlined in the table below.

Table 3. Germany’s recycling targets for different material categories.

(Source: Verpackungsgesetz, 2020, Der Grüne Punkt, n.d.)

The Act also sets future targets to expand its coverage.

1. From 2023, caterers, delivery services and restaurants are obligated to offer reusable containers for takeaway food and beverages in addition to disposable ones.

2. From 2025, non-refillable PET beverage bottles must contain at least 25% recycled plastic content. From 2030, this quota will be increased to at least 30%.

The EPR system under the Packaging Act is designed to incentivise the utilisation of recyclates, renewable raw materials, and materials with high recyclability rates. These incentives are intended to be reflected in the participation or licence fees to the system operator, which will be determined based on ecological criteria over the medium term, also known as modulated licence fees. The specific criteria for these fees will be defined by the Central Agency under the supervision of the Environment Agency.

Roles and Responsibilities

Table 4. Roles and responsibilities under Germany’s EPR scheme for packaging.

Overview

Managing plastic waste in Canada presents a complex challenge influenced by the country’s unique governance structure and environmental context. While the federal government establishes overarching principles and coordinates strategic direction through action plans, the implementation of Extended Producer Responsibility (EPR) and other waste management initiatives primarily falls under provincial and territorial jurisdiction. Efforts to harmonise EPR policies across the country are ongoing, including the creation of the Federal Plastics Registry. However, the decentralised approach underscores the importance of understanding provincial acts and regulations to evaluate EPR implementation progress as Canada advances towards its goal of zero plastic waste by 2030.

EPR vs Product Stewardship

To tackle its plastic waste issue, provinces in Canada have implemented either EPR or Product Stewardship programmes to manage products at the end of their life cycle:

• EPR Programmes: These designate the end-of-life management of products as the responsibility of producers (e.g., brand owners, first importers, or manufacturers). Funding for EPR programmes is provided by producers, with costs either internalised as a factor of production or passed on to consumers.

• Product Stewardship Programmes: Unlike EPR, financial responsibility is typically not placed on the producer. Instead, these programmes allocate responsibility to provincial, territorial, or municipal governments, often relying on legislated environmental fees or public funds.

To promote national consistency, the Canadian Council of Ministers of the Environment (CCME) has developed the Canada-wide Action Plan for Extended Producer Responsibility in October 2009. This plan encourages a coordinated approach and collaboration amongst provinces, establishes benchmarks, and aims to shift product stewardship initiatives into comprehensive EPR programmes across the nation.

Provincial and Territorial EPR Efforts

As waste management and recycling programmes in Canada fall under the jurisdiction of individual provinces and territories, each province’s EPR framework combines federal guidance with provincial implementation to address local needs while aligning with national goals.

Currently, Canada has nine active EPR laws for packaging, each with different timelines, covered materials, and structures. Notable exceptions include Prince Edward Island, Newfoundland and Labrador, Nunavut, and the Northwest Territories, which have yet to establish formal EPR frameworks.

The table below summarises key information for each province and territory regarding EPR laws for packaging in Canada:

Mechanism of EPR Implementation

Most EPR programmes in Canada require obligated producers to register with each of their province’s regulatory or authority body individually or join a Producer Responsibility Organisation (PRO) to report packaging data and pay fees to sell their products.

PROs are typically not-for-profit organisations or industry associations designated by a producer or group of producers to manage and administer an EPR or product stewardship programme on their behalf. In Canada, PROs may also be referred to as ‘stewardship organisations,’ ‘industry funding organisations,’ or ‘delegated administrative organisations.’ The fees collected by PROs directly support infrastructure development for the collection, recycling, and environmentally responsible disposal of packaging materials.

To fulfil their obligations, producers must:

1. Collect packaging data: Gather detailed information on packaging materials placed on the market in each relevant jurisdiction.

2. Report data to the relevant regulatory or authority body: Submit accurate data to the relevant regulatory or authority body directly or through a PRO.

3. Pay EPR fees: Make payments directly or through a PRO based on predetermined fee structures, funding waste management systems.

Obligated Producers

In Canada, the definition of a producer may slightly differ in each province. Generally, the Environment and Climate Change Canada (ECCC) defines a ‘producer’ of packaging as any entity supplying packaging materials to consumers, including brand owners, first importers, manufacturers, distributors, or suppliers of products and packaging. Producers are responsible for managing the end-of-life of the packaging they introduce to the market, ensuring these materials are collected, recycled, or disposed of responsibly. When legally obligated to recover and recycle their products and/or packaging at the end of their life cycle, these producers are referred to as ‘industry stewards.’

Obligated Entities Based on Responsibility Hierarchy

The entity responsible for fulfilling EPR requirements in Canada is generally determined through a hierarchical structure. While the hierarchy may vary across provinces, the resident brand holder/owner typically assumes the obligation for packaging and paper products (PPP) in all jurisdictions. If the brand holder/owner does not meet residency requirements, the obligation falls to the resident first importer, who may be a distributor, retailer, or marketplace facilitator in certain jurisdictions. In franchise businesses, the franchisor is responsible for all packaging and paper generated by franchisees, regardless of the location of the head office. Generally, the hierarchy follows the structure below, though it may vary by province:

1. Brand Owners:

   • The first obligated party is the manufacturer or company that owns the brand of the product being packaged.

   • If the brand owner is a resident of Canada, they are deemed the producer.

2. Importers:

   • If the brand owner is not a Canadian resident, the responsibility shifts to the first entity importing the products and their packaging into the reporting province.

3. Retailers:

   • If no brand owner or importer is identifiable, the retailer supplying the packaging to consumers becomes the obligated producer.

Additional Responsibilities:

1. Marketplace Facilitators:

   • If the retailer considers the producer as a marketplace seller, the marketplace facilitator then assumes the role of the obligated producer.

2. Franchises:

   • For franchise businesses, the franchisor is regarded as the obligated producer in every province where it has franchisees.

Products Covered under EPR

The table below summarises EPR coverage across Canadian provinces and territories as of February 2025 for key product categories – including packaging & paper, printed paper, electronics, beverage containers, paint, food‐service packaging, single‐use plastics, tires, and textiles – with notes on single‐use plastic bans. The table compiles the best available information and highlights nuances such as Alberta’s partially implemented framework, the federal (rather than provincial) ban on certain single‐use plastic items, and the ongoing phase-in of new EPR regulations in provinces like Alberta and Ontario.

Products Covered under EPR in Canada (as of February 2025)

• Yes = Province/Territory has a mandatory EPR/stewardship programme covering this product.

• Partial = Coverage is limited or in development (e.g., pilot programmes, municipal bylaws, or pending provincial regulations).

• No = No province‐wide mandatory EPR for this category.

• (deposit) under Beverage Containers = Province/Territory operates a deposit‐refund system (often called ‘stewardship’ rather than EPR but effectively places responsibility on producers/consumers).

In many jurisdictions, packaging and paper as well as printed paper are managed under a single EPR programme, as seen in provinces like British Columbia, Saskatchewan, and Manitoba. A ‘Yes’ indicates the presence of a mandatory EPR or stewardship programme, while ‘Partial’ suggests that only pilot programmes exist or regulations are still pending – in Alberta, for example.

Nearly all provinces and territories, except for Nunavut, employ a deposit-refund system for beverage containers. Although this system is sometimes labelled as ‘stewardship’ rather than EPR, it effectively transfers costs to producers and consumers through deposits and refunds.

At the federal level, the Single-Use Plastics Prohibition Regulations (SOR/2022-138) ban or restrict the manufacture, import, and sale of certain items, including plastic checkout bags, cutlery, stir sticks, straws, ring carriers, and specific foodservice products. However, this is not a comprehensive ban on all single-use plastics, and no province or territory has implemented a broader ban beyond these federal measures.

National Strategies and Commitments

The Canadian Council of Ministers of the Environment (CCME), an intergovernmental group of federal, provincial, and territorial environment ministers, has championed extended producer responsibility (EPR) since the late 1990s. To promote harmonised policies and coordinated actions, the CCME published the Canada-wide Action Plan for Extended Producer Responsibility, outlining key principles:

• Encourage producers to design environmentally sustainable and health-conscious products.

• Shift end-of-life waste responsibility from municipalities to producers and importers.

• Make producers and importers accountable for programme design, operation, and funding.

• Assign governments the roles of setting performance targets, ensuring fairness, and providing public access.

In November 2018, the CCME adopted the Canada-wide Strategy on Zero Plastic Waste, building on the Ocean Plastics Charter. The strategy follows a circular economy approach and provides a framework for reducing plastic waste. To implement it, the federal, provincial, and territorial governments introduced the Canada-wide Action Plan on Zero Plastic Waste, developed in two phases:

• Phase 1 (2019): Focused on improving plastic circularity and driving systemic change to reduce waste.

• Phase 2 (2020): Aimed at reducing pollution, raising awareness, strengthening research, and advancing global action.

Canadian Federal Plastics Registry

In April 2024, Environment and Climate Change Canada (ECCC) announced the creation of the Federal Plastics Registry through a Section 46 notice published in the Canada Gazette, Part I. The registry aims to establish consistent, comprehensive, and transparent EPR across Canada by gathering data on plastics to support research, inventory creation, and the development of objectives, codes of practice, guidelines, and environmental assessments. This standardised information – covering plastics from production to end-of-life – will help inform and measure actions to reduce plastic pollution and ultimately hold producers accountable for the entire life cycle of their plastic products. The data collection aligns with the Canadian Environmental Protection Act, 1999, specifically Section 46, Part 1, and adheres to the CCME guidance. The registry is a key commitment under Phase 1 of the Canada-wide Action Plan on Zero Plastic Waste, which seeks to establish uniform EPR policies and programmes for plastics.

Efforts to develop the Federal Plastics Registry have been guided by extensive public consultation. On 25 July 2022, a consultation paper was released to gather feedback on reporting plastics in the Canadian economy. This included a 70-day comment period and webinars to engage stakeholders. In April 2023, a technical paper outlining reporting requirements was published, accompanied by a 30-day public comment period.

Most recently, on 30 December 2023, a draft Section 46 notice and Notice of Intent were published in the Canada Gazette, Part I, inviting feedback during a 45-day comment period that ended on 13 February 2024. Input from these consultations, summarised in a report published in February 2023, had been integral to shaping the Section 46 notice.

New Reporting Requirements for Producers

The Federal Plastics Registry will introduce new reporting obligations for companies, including resin manufacturers, service providers, and producers of plastic products. These companies must report annually to Environment Canada on the quantity and types of plastics they manufacture, import, and place on the market.

Additionally, producers and service providers will need to report on the volume of plastics collected for diversion, reuse, repair, remanufacturing, refurbishment, recycling, chemical processing, composting, incineration, and landfilling. Companies generating packaging or plastic product waste will also need to report on the amount of waste produced at their industrial, commercial, and institutional premises.

This reporting process is being phased in over several years, starting with the 2024 calendar year. From 2025 onwards, companies must retain all relevant records, calculations, and data for at least three years from the submission date. EPR reporting deadlines for packaging in Canada will be set annually on 29 September, starting in 2025.

The categories of plastics that will be subject to reporting include all resins and products listed in Parts 1 through 4 of Schedule 1 to the Notice (‘Schedule 1’), whether manufactured, imported, or placed on the market in Canada. More detailed subcategories can be found in the Notice. Examples are shown in the table below:

There are three key exemptions to these reporting requirements, designed to ease the burden on small businesses or those with minimal involvement in the plastics industry:

• Businesses that manufacture, import, or place on the market less than 1,000 kg of plastic products or packaging annually.

• Small waste generators, producing less than 1,000 kg of plastic waste at industrial, commercial, or institutional (IC&I) facilities.

• Small waste managers, including service providers managing less than 1,000 kg of plastic through collection, recycling, or disposal activities.

Ongoing Challenges and Innovation

Despite these initiatives and programmes, challenges remain. As of March 2023, plastic waste in Canada increased by 23% between 2012 and 2018, rising from 5,158 kilotons (kt) to 6,323 kt. In 2019, Canada discarded approximately 4,364 kt of plastic, with only 1,330 kt (9%) recycled – resulting in 402 kt of recycled plastic resins for manufacturers – while the remainder ended up in landfills, waste-to-energy facilities, or the environment.

In line with its commitment to tackle plastic pollution, the Government of Canada introduced the Single-use Plastics Prohibition Regulations (SUPPR) in June 2022, officially banning the manufacturing, import, and sale of six specific single-use plastic items due to their toxicity. However, in November 2023, the Federal Court ruled that the Order adding ‘plastic manufactured items’ to Schedule 1 of the Canadian Environmental Protection Act (CEPA) was invalid. The court argued that the terms were too broad, lacked evidence that all plastic items are toxic, and exceeded the federal government’s legal authority. In January 2024, the Federal Court of Appeal issued a stay, temporarily halting the court ruling while the government appeals the decision, which is still ongoing.

Canada continues to invest in research and innovation to develop plastic alternatives and advanced recycling technologies and infrastructure, including chemical recycling and biodegradable plastics. The government is also engaging with industries and communities to raise awareness and promote education on plastic waste reduction.

The Innovative Solutions Canada programme has funded several companies developing advanced sorting technologies and new plastic alternatives. Canadian companies are at the forefront of producing high-value products made from recycled plastics, including durable construction materials and new packaging solutions. These efforts contribute to the growth of the circular economy and reduce the demand for virgin plastics.

Public education and community engagement such as the Zero Plastic Waste Initiative, launched by the Canadian government, aims to encourage citizens to adopt sustainable practices, such as reducing single-use plastics and participating actively in recycling programmes. Through this initiative, the government is working with municipalities and businesses to enhance waste collection and sorting infrastructure, ensuring that more materials are recycled and diverted from landfills.