Fourteen business associations recently contributed ideas to the Prime Minister’s draft decision on reasonable and lawful Fs, and made proposals on deploying financial contributions for recycling responsibility in Extended Producer Responsibility (EPR).

The associations said they had committed to support the Ministry of Natural Resources and the Environment (MONRE) in efforts to protect the environment and accelerate product and package recycling to promote the green and circular economy in Vietnam.

However, they believe that recycling costs shown in the draft are unreasonably high because the value of recalled products according to the principles of the circular economy is not deducted and the data indicates many shortcomings.

The documents attached to the draft show that Fs is the average value between two results – the recommendations of experts from IFC (International Monetary Corporation) and WWF (World Wide Fund For Nature), and proposals of the Vietnam Waste Recycling Association.

The gap between the two proposals is wide because of different component expense items.

Moreover, the associations pointed out that the Fs stipulated in the draft are not reasonable and they are much higher than the average levels of other countries. 

This is because the document compilers only considered studies with the highest Fs and skipped the other two studies with lower Fs.

The formula the compilers used to calculate Fs in the draft decision ignores the profits enterprises can expect to collect from recycled materials. 

Therefore, the proposed Fs are unreasonable and are not in line with the principles of the circular economy.

The draft decision recommends Fs of 0.3 for paper, PET bottle and aluminum; and 0.5 for steel in order to reduce Fs for materials with high collectable value. 

The proposed Fs is unreasonable because the recyclers of these materials all can make profits from recycling, and the value of materials to be collected are clearly higher than recycling costs.

Material recycling creates jobs and profits for recycling enterprises. In general, all the materials of products can be called back, so there is little risk to the environment.

Thus, it is unreasonable to request manufacturers to pay money to support recyclers, while recyclers make a profit from recycling activities. 

The value of the materials to be collected is higher than the recycling cost, so in accordance with the principle of a circular economy, Fs must be zero.

Tran Chung