Vietnam's EPR regulations increase the stakes for recyclers of waste oil

Lubricant marketers and importers in Vietnam are now subject to stricter recycling requirements under a consolidated Extended Producer Responsibility (EPR) framework that came into force in May 2026. The regulatory update coincides with growing industry efforts to establish harmonized sustainability standards across Asia and facilitate cross-border trade in re-refined base oils (RRBO).

Vietnam's Decree No. 110/2026/ND-CP, issued on 1 April 2026 and effective from 25 May 2026, brings together previously dispersed EPR regulations into a unified framework governing the responsibilities of manufacturers and importers. The decree requires obligated parties to either organize the collection and recycling of products, including engine oils, engage licensed recyclers, or contribute financially to the Vietnam Environmental Protection Fund. Companies generating annual revenue of less than VND 30 billion (approximately USD 1.14 million) from covered products may be eligible for exemption.

Under the new rules, producers and importers must submit annual recycling plans or declare their financial contributions by 1 April for products sold in the previous year, with payments due by 20 April. Mandatory recycling targets will be reviewed every three years, with any increase limited to a maximum of 10%. The first review is expected in 2029.

The regulatory developments align with the release of a white paper by the Asian Lubricants Industry Association (ALIA) in March 2026 titled Circular Lubricants – Opportunity for a Harmonised Approach to Sustainability Across Asia. The Singapore-based association, representing around 100 companies across the lubricant value chain, advocates for common sustainability principles and mutual recognition of quality standards for re-refined base oils throughout the region.

Speaking during an ALIA webinar on 15 May, Eric Holthusen, Senior Technical Advisor at ALIA and Director of Technology at Petrolube Group, said the objective is not to impose identical regulations across countries but to establish shared definitions and quality benchmarks. Such alignment, he noted, would enable the seamless trade of re-refined base oils across Asian markets while ensuring consistent product quality for lubricant blenders.

The white paper highlights the distinction between re-refined base oil and conventionally recycled oil. While recycled oil typically undergoes basic physical treatment and is generally used in lower-specification applications, RRBO is produced through advanced processes such as vacuum distillation and hydrotreating. When properly re-refined, RRBO can achieve quality levels comparable to virgin base oils and may meet API Group I, Group II, or Group III specifications, depending on the technology employed. The report also emphasizes that not all RRBO grades are interchangeable.

According to ALIA, Vietnam's EPR framework is expected to gradually increase recovery targets for lubricating oil materials from approximately 15% toward 20%, while integrating licensed re-refiners into national recovery programs. Charlotte Kehoe, Chair of the ALIA Council and Technology & Sustainability Director at Castrol ASPAC, noted that some governments are taking a more active role in determining which recyclers qualify under EPR schemes, citing Vietnam as a leading example of this approach.

The detailed article is published by https://www.fuelsandlubes.com/ can be accessed from https://www.fuelsandlubes.com/vietnam-epr-rules-raise-stakes-for-waste-oil-recyclers/