According to the petition, there are some outstanding shortcomings that need to be recalculated to be consistent with reality and international practices. Specifically, the recycling cost norms in the draft are calculated based on consultation studies with very different results, so they are not reliable. Furthermore, the proposed recycling cost norms in the draft are unreasonable and are much higher than the average level of other countries.
The business community believes that the draft on recycling still has many points that need to be revised to suit actual conditions.
In addition, the formula for calculating recycling costs as in the current draft completely ignores the profit factor of the recycling enterprise from recycled materials, or the recovered value of the packaging. Therefore, the proposed recycling cost does not follow the circular economy principle because it does not deduct the value of recovered materials.
In addition to the above suggestions, the associations also have 4 recommendations. Firstly, there should be preferential policies for environmentally friendly packaging or packaging using recycled materials. This will encourage businesses to use recycled materials in packaging, increase resource efficiency, reduce dependence on virgin materials in production, create output for the recycling industry and help promote the development of the recycling industry in Vietnam, which is decisive in promoting the circular economic model.
Second, change the way the fund is paid, accordingly, the actual amount will be settled at the end of the year, instead of making an advance payment at the beginning of the year, to both fully fulfill the responsibility to the environment and reduce difficulties for businesses. This proposal is also consistent with Resolution No. 58/NQ-CP dated April 21, 2023 of the Government directing: "Support cost reduction for businesses", "resolutely and effectively implement support solutions on taxes, fees, charges, land rents..." to support businesses in the current particularly difficult period.
The third is to allow businesses to combine both self-recycling and recycling support payments in the same year, instead of forcing them to choose one of the two methods.
Finally, in the first two years (2024 and 2025), focus on implementation instructions, do not apply penalties, only collect underpayments if businesses do not declare fully or incorrectly, except in cases of intentional non-declaration or intentional fraud.
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