EPR and Responsible Sourcing in Plastic Packaging Recycling: Two Additive, Non-Interchangeable Costs

Plastic packaging producers and importers in Vietnam now face two parallel but fundamentally different cost frameworks: the domestic EPR recycling-cost norm (Fs), and the international Responsible Sourcing cost. A new comparative study (20 August 2026), extending an earlier working paper on Fs for the lubricants – tires – road vehicles group, for the first time puts both frameworks on the same unit of measurement to compare them for PET and HDPE plastic packaging.

Two numbers, two different natures

Fs for rigid PET packaging, per the norm published by PRO Vietnam under Circular 07/2025/TT-BTNMT, is VND 1,979/kg — a mandatory legal obligation if a company opts to make a financial contribution to the Vietnam Environmental Protection Fund. The Responsible Sourcing cost, per the study by The Circulate Initiative (India, Kenya), converts to only about VND 1,040–1,300/kg — but it is a voluntary investment, driven by buyer requirements and export markets, and not yet codified into Vietnamese law.

Paying Fs does not mean meeting responsible-sourcing standards

The current Fs formula prices technical steps (sorting, collection, transport, recycling) and has no dedicated cost line for the rights of informal waste collectors — which is precisely the focus of the Harmonized Responsible Sourcing Framework. As a result, a company can fully meet its Fs obligation while still falling short of the social-responsibility standards global brands require. Conversely, investing in responsible sourcing does not reduce a company's Fs obligation. The two costs are additive, not interchangeable.

A recommendation for businesses

Companies should keep two separate budget lines — a “minimum compliance cost” (Fs, applied to the full volume of packaging placed on the market) and an “above-standard investment cost” (Responsible Sourcing, applied to the share of recycled plastic that needs to meet international standards). Merging the two easily leads to either overstating or understating the real cost when negotiating with ESG-committed buyers.

The study also flags points that warrant further verification: the conversion exchange rate is a point-in-time figure, and the Responsible Sourcing baseline of US$40–50 per tonne is drawn from the India – Kenya context, serving only as a directional reference for the Vietnamese market.

Sources: Decree 110/2026/NĐ-CP; Circular 24/2026/TT-BNNMT; Circular 07/2025/TT-BTNMT; The Circulate Initiative & Responsible Sourcing Initiative (6/2026); internal working papers (7 August 2026 and 20 August 2026).