Legislation on E-waste Management from the EPR Perspective: Chinese Experience and Recommendations for Improving Vietnamese Legislation

Abstract: This paper analyzes the legal framework and practical implementation of EPR in e-waste management in Vietnam, comparing it with the experience of China, a country that has built a systematic EPR model, operating through specialized documents, centralized financial funds and digital monitoring mechanisms. Based on the identification of Vietnam's limitations such as lack of recycling infrastructure, lack of data, weak collection mechanism and lack of individualization of corporate responsibility, the study proposes directions for improving the law according to the following contents: designing policy tools, developing infrastructure, technology, improving collection mechanisms and expanding the scope of e-waste management in accordance with the circular economy.

Keywords: E-waste, EPR, China's experience, improving the law.

I. Introduction

Electronic waste is currently the fastest-growing waste stream globally, with the volume generated in 2022 reaching approximately 62 million tonnes and projected to increase to 82 million tonnes by 2030. Although it contains many high-value materials such as gold, silver, and copper, with an estimated total value of USD 60 billion per year, only about 22.3% of electronic waste is properly collected and recycled.[2] The remaining volume is largely disposed of in open dumps, illegally landfilled, or processed within the informal sector, posing significant risks to public health and the environment.[3]

In this context, extended producer responsibility (EPR) is regarded as an effective legal instrument to shift the burden of waste management from the State to entities placing products on the market. China is one of the countries that has implemented EPR at an early stage and achieved substantive results through the establishment of coordinated financial and technical mechanisms, formal collection and recycling systems, and centralized supervision platforms. In Viet Nam, EPR is recognized in the Law on Environmental Protection 2020 and Decree No. 08/2022/ND-CP; however, its practical implementation remains limited, as reflected in shortcomings such as the lack of data, inadequate supervision mechanisms and sanctions, and unsynchronized collection and recycling infrastructure. Therefore, examining China’s experience for comparison and drawing recommendations for improving the legal framework is necessary in order to enhance the effectiveness of electronic waste management and meet the requirements of international integration.

II. Theoretical basis of EPR in the management of electronic waste

According to the United Nations’ Solving the E-waste Problem (StEP) Initiative, electronic waste is defined as: “Electrical and electronic equipment and their parts that are discarded by the owner with no intention of reuse.”[4] The Global E-waste Monitor 2024 (ITU/UNITAR) also emphasizes the dual nature of electronic waste: on the one hand, it constitutes a valuable resource with a high content of recyclable metals and materials; on the other hand, it contains numerous hazardous substances such as lead, mercury, and cadmium which, if not properly treated, may cause environmental pollution and adversely affect public health.[5]

In Viet Nam, Decision No. 16/2015/QD-TTg on the collection and treatment of discarded products is the first legal instrument to address post-consumer electrical and electronic products as a category of waste requiring recycling and treatment. Although this instrument does not provide a direct definition, it paved the way for the formation of a legal framework for the management of electronic waste. Within the current environmental legal system, electronic waste is regarded as a specific category of waste that is both recyclable and potentially hazardous, thus requiring a separate and stringent management mechanism.

From the perspective of this study, electronic waste may be broadly defined as electrical and electronic products and equipment and their components that have reached the end of their life cycle and are discarded by the owner with no intention of reuse.

Extended producer responsibility is considered an effective environmental policy instrument that links the responsibility of producers to the entire product life cycle. According to the Organisation for Economic Co-operation and Development (OECD), EPR is an approach under which the responsibility of producers does not end at the stage of placing products on the market but is extended to the post-consumer stage, including the take-back, recycling, and treatment of products.[6] This mechanism shifts the financial burden from the public sector to the private sector, while at the same time encouraging enterprises to improve product design in a more environmentally friendly manner.

At the regional level, Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) of the European Union has concretized the EPR principle by requiring producers to bear comprehensive responsibility for electrical and electronic products after the end of their life cycle, including collection, treatment, and recycling.[7]

In Viet Nam, the law does not provide a direct definition of EPR; however, this content is indirectly reflected through the Law on Environmental Protection 2020 and its implementing instruments. Specifically, Articles 54 and 55 of the Law on Environmental Protection 2020 establish the obligations of producers and importers to recycle post-consumer products and packaging or to make financial contributions to support waste collection and treatment activities. The core of this mechanism lies in the transfer of responsibility and costs of waste treatment from the public sector to entities placing products on the market, thereby giving concrete expression to the “polluter pays” principle.[8]

From a legal-theoretical perspective, EPR therefore is not merely a single legal obligation imposed on producers and importers, but may also be viewed as a mechanism for reallocating responsibilities between the State and the private sector in the management of electronic waste. Accordingly, while the Law on Environmental Protection 2020 places recycling obligations and financial responsibility for post-consumer products on producers and importers,[9] Article 164 of the Law on Environmental Protection 2020 identifies the role of the State as focusing on the promulgation and organization of the implementation of policies and laws; the development of standards and technical regulations; and the control, inspection, examination, and supervision of environmental protection activities. This allocation demonstrates that under the EPR mechanism, the State assumes a facilitating, regulatory, and enforcement-guaranteeing role, whereas financial responsibility and responsibility for organizing the implementation of post-consumer product management are shifted to producers and importers pursuant to Articles 54 and 55. This approach is consistent with the views of the OECD[10] and the EPR model under European Union law,[11] and reflects the broader trend of transferring financial and organizational responsibilities from state management authorities to producers in environmental governance.[12]

On that basis, EPR is not only significant as a purely legal mechanism but also plays an important role in promoting the circular economy. By linking corporate responsibility to the entire product life cycle, EPR creates incentives for recycling and material reuse, limits the exploitation of natural resources, and reduces waste generation.[13] At the same time, EPR contributes to controlling risks arising from hazardous components in electronic waste, mitigating pollution, and enhancing the effectiveness of environmental protection.[14] Overall, EPR functions both as an instrument for enforcing legal principles and as a lever for transforming development models towards green and sustainable pathways.

III. Legal regulations and practical implementation of EPR in the management of electronic waste in Viet Nam 

3.1. Legal framework governing EPR for electronic waste

The legal framework governing electronic waste in Viet Nam is built upon the Law on Environmental Protection 2020, in which the EPR mechanism is established as a central management pillar. Although the Law does not provide a direct definition, EPR is structured through two core groups of management obligations: (i) mandatory recycling obligations applicable to groups of recyclable products and packaging, including multiple categories of electrical and electronic products; and (ii) the obligation to make financial contributions to the Viet Nam Environmental Protection Fund in cases where producers and importers do not organize recycling themselves. These obligations are specified in Clause 2, Article 54 of the Law on Environmental Protection 2020, clearly reflecting the foundational management principle of the “polluter pays” principle, with the aim of reallocating the costs of electronic waste management from the public sector to waste-generating entities.[15]

To operationalize the provisions of the Law, the Government promulgated Decree No. 08/2022/ND-CP[16], which serves as the most important implementing instrument for EPR. The Decree clearly stipulates: the list of electrical and electronic products subject to mandatory recycling[17]; the application roadmap by product groups[18]; methods for calculating recycling norms[19]; financial contribution obligations[20]; and requirements for reporting, registration, and information disclosure to serve state management activities.[21] Decree No. 08/2022/ND-CP not only links recycling responsibility with financial obligations, but also establishes a multi-tier management mechanism, comprising the Viet Nam Environmental Protection Fund, systems for inspection and supervision of recycling activities, and an electronic reporting regime.

The legal framework has continued to be refined through Decree No. 05/2025/ND-CP, which amends certain provisions of Decree No. 08/2022/ND-CP. The promulgation of Decree No. 05/2025/ND-CP reflects the Government’s proactive approach to improving the EPR management framework following the initial implementation phase of Decree No. 08/2022/ND-CP. The amendments focus on addressing practical bottlenecks, such as clarifying responsible entities, adjusting exemption criteria, specifying conditions applicable to recycling entities and authorized parties, and simplifying procedures while shortening the time required for publication on the EPR system. These adjustments contribute to enhancing transparency, reducing compliance risks for enterprises, and creating a more feasible EPR operational mechanism, particularly for sectors generating large volumes of waste, such as electrical and electronic products. Overall, Decree No. 05/2025/ND-CP represents a timely regulatory adjustment aimed at strengthening the effectiveness of state management and providing a more stable foundation for EPR implementation in subsequent phases.

In addition, to ensure the consistent and transparent operation of the EPR mechanism, the State has established a series of key governance institutions, including the National EPR Council pursuant to Decision No. 252/QD-BTNMT[22]. This is an inter-sectoral coordinating body whose primary function is to assist the Minister of Natural Resources and Environment in managing, supervising, and supporting the implementation of recycling responsibilities for products and packaging, as well as waste collection and treatment responsibilities of producers and importers. The Council was further consolidated under Decision No. 2235/QD-BTNMT dated 08 August 2023, promulgating the regulations on the organization and operation of the National EPR Council, thereby reinforcing its role as a central advisory and supervisory body. It can be observed that Viet Nam has established a relatively comprehensive, multi-tier legal framework that integrates substantive rules, technical standards, sanctions, and institutional arrangements, thereby laying the groundwork for the operation of EPR in electronic waste management in a manner aligned with international integration and convergence with international standards.

3.2. Practical implementation and limitations in the enforcement of EPR in Viet Nam

Although Viet Nam has initially established a relatively comprehensive legal framework to regulate electronic waste management and implement the EPR mechanism, the current legal system still reveals a number of shortcomings in terms of feasibility, coherence, and enforcement capacity.

First, the legal framework remains fragmented and lacks a dedicated sector-specific regime for electronic waste

While the Law on Environmental Protection 2020 has laid an important foundation for the EPR mechanism, provisions relating to electronic waste are currently only incorporated into part of Appendix XXII of Decree No. 08/2022/ND-CP, together with numerous other product groups. This indicates that Viet Nam is adopting a universal approach to EPR, but has not yet developed a sector-specific legal instrument dedicated exclusively to waste electrical and electronic equipment, as has been done in several jurisdictions worldwide, such as China and the European Union. The absence of an independent and specialized legal framework has limited the extent to which electronic waste management is aligned with the particular environmental risks and complex life cycles inherent in this category of waste.

Second, EPR-related regulations lack stability, coherence, and consistency

First, the scope of regulation and the entities subject to EPR obligations have been subject to frequent adjustments through decrees and amending instruments. A typical example is Decree No. 08/2022/ND-CP, which, shortly after its promulgation, required further refinement through Decree No. 05/2025/ND-CP to clarify a series of technical issues such as product lists, declaration methods, and financial contribution procedures.[23] This practice demonstrates that the foundational EPR provisions have not yet achieved the level of stability necessary for effective implementation, thereby creating difficulties for enterprises in forecasting their obligations and formulating long-term compliance strategies.

In addition, policies concerning exemptions from recycling obligations, reuse activities, and the recognition of recycling outcomes have changed relatively rapidly through guiding documents and updates issued by regulatory authorities. Several regulations on minimum recycling rates, recycling cost norms, and financial contribution levels to the Viet Nam Environmental Protection Fund have also been subject to continuous review, increasing uncertainty in determining producers’ obligations, particularly for electrical and electronic products characterized by short life cycles and significant market volatility.[24]

Third, EPR monitoring and enforcement mechanisms remain weak and are not supported by a unified data system

Although regulations on inspection and reporting responsibilities have been introduced, detailed guidance on data verification, reconciliation of recycling outputs, and validation of the accuracy of reports has not yet been fully established. Notably, Viet Nam has not developed an official and regularly updated electronic waste inventory database, resulting in the absence of a reliable basis for tracking waste generation volumes, collection rates, and recycling performance.[25] The lack of standardized data makes it difficult for regulatory authorities to cross-check information, detect non-compliance, and undermines the transparency of the entire EPR system.

In addition, pursuant to Article 80 of Decree No. 05/2025/ND-CP (as amended), the mechanism for verification and authentication of recycled quantities largely relies on self-declaration by enterprises and documentation provided by recycling facilities, while detailed provisions on independent verification procedures have yet to be established.[26] The absence of detailed technical guidance on counting, measurement, and recognition of recycled quantities increases the risk of data inaccuracies and further reduces the transparency of the mechanism.

Fourth, limitations in controlling the collection and recycling of electronic waste

The most significant challenge is that the State has not yet been able to control the sources and flows of electronic waste, resulting in the failure to establish a stable and sufficiently large input supply for the formal recycling sector. The majority of discarded electronic equipment is collected by informal actors such as scrap dealers, repair technicians, waste traders, and dismantling craft villages. These activities operate outside governmental oversight and do not comply with environmental standards, leading to the dismantling of electronic waste in a manner that maximizes short-term economic gains without the application of appropriate technologies.[27] This situation places formally licensed recycling enterprises - which are subject to extensive environmental obligations and high operating costs - at a competitive disadvantage vis-à-vis the informal sector, while also preventing them from securing sufficient feedstock to operate modern recycling technologies.

Another challenge lies in the limited public awareness of electronic waste as hazardous waste. Obsolete devices are often regarded as assets with residual resale value rather than waste requiring safe treatment. Even formal collection initiatives such as Vietnam Recycles (VRP), one of the few non-profit models operating in Viet Nam, have been able to collect only a very small proportion of the total electronic waste generated.[28] This indicates that the current legal framework lacks effective mechanisms to promote household-level separation and return of electronic waste, despite households being the primary source of waste generation.

Management efforts are further constrained by the absence of a mandatory legal framework or coercive instruments to control spontaneous collection and dismantling activities. Although technical requirements exist for licensed recycling facilities, the law does not provide sufficiently strong sanctions to restrict or transform informal recycling activities into the formal sector. As a result, electronic waste continues to be concentrated primarily in craft villages, where treatment costs remain low due to the non-fulfillment of environmental obligations, thereby creating unfair competition with industrial-scale facilities.

Fifth, the absence of direct support mechanisms for electronic waste collection and recycling enterprises

The Law on Environmental Protection 2020 (Articles 54 and 55) clearly stipulates the obligations of organizations and individuals in the recycling, collection, and treatment of discarded products and packaging, including electronic waste. However, the Law and its subordinate instruments - such as Decree No. 08/2022/ND-CP, Decree No. 05/2025/ND-CP (as amended), and Circular No. 02/2022/TT-BTNMT - primarily focus on establishing mandatory obligations and technical requirements, including recycling rates, product specifications, and declaration and monitoring procedures. Although Decree No. 05/2025/ND-CP represents progress by introducing certain incentives related to corporate income tax, import tax, and export tax for recycling and waste treatment activities,[29] direct financial support policies, green credit schemes, land-use incentives, or technology innovation incentives specifically tailored to electronic waste recycling enterprises remain insufficiently articulated and implemented. This limitation constrains the capacity for systematic investment in modern recycling systems and reduces incentives for enterprises to engage more deeply in EPR implementation.

IV. China's experience in implementing EPR in the management of electronic waste

China is one of the world’s largest consumers and disposers of electrical and electronic equipment, with more than 1.1 billion users and production activities concentrated in major industrial centers such as Guangdong, Zhejiang, Jiangsu, Beijing, and Shanghai.[30] The rapidly increasing volume of electronic waste has compelled the Chinese Government to establish a comprehensive management framework based on the EPR principle, aimed at controlling the product life cycle from production to disposal. Within a system of state management characterized by a relatively high degree of centralization, EPR in China has been implemented through more centralized coordination mechanisms, with the State playing a prominent role in setting standards, authorizing treatment facilities, designing subsidy schemes, and supervising compliance.[31] The central objective of EPR in China is to shift end-of-life treatment and recycling responsibilities from the State to the production and business sectors, while at the same time encouraging enterprises to adopt eco-design practices and reduce environmental pollution. From an overall perspective, EPR is regarded as one of the key policy instruments for promoting the circular economy and controlling emissions in the electrical and electronic sector. Accordingly, China’s experience in implementing EPR can provide an important reference for policy refinement; however, the selection and application of specific instruments must be considered in light of each country’s institutional context and enforcement capacity, including that of Viet Nam.

4.1. Legal framework and institutionalization of the EPR principle in the management of electronic waste

The legal framework governing EPR for electronic waste in China is established on the basis of multiple foundational legal instruments, forming a coherent and comprehensive institutional system.

(1) Law on the Promotion of Cleaner Production (effective from 1 January 2003) [32]:This Law focuses on pollution prevention at the design and production stages, requiring enterprises to apply resource-efficient production processes, minimize waste generation, and use environmentally friendly materials. From an EPR perspective, the Law promotes eco-design, aiming to extend product lifecycles and reduce the generation of electronic waste.

(2) Law on the Promotion of the Circular Economy (effective from 1 January 2009) [33]:This Law institutionalizes the principles of reduction, recycling, and recovery, thereby establishing a legal framework for the development of closed-loop systems in the management of electrical and electronic products. It clearly stipulates the responsibilities of manufacturers for the take-back and recycling of end-of-life products, contributing to the nationwide implementation of EPR.

(3) Law on the Prevention and Control of Environmental Pollution by Solid Waste (amended in 2020, effective from 1 September 2020) [34]:This Law was enacted with the objectives of protecting and improving the ecological environment, preventing and controlling pollution caused by solid waste, safeguarding public health, maintaining ecological security, and promoting sustainable socio-economic development. From an EPR perspective, the Law expands its regulatory scope to include electronic waste, batteries, and vehicles, thereby establishing clear legal responsibilities for manufacturers and importers with respect to the collection, recycling, and treatment of end-of-life products.

(4) Regulation on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products (Decree No. 551, effective in 2011):This instrument functions as a “framework regulation” marking a significant turning point in the management of waste electrical and electronic equipment in China, as it was the first to establish a sector-specific, mandatory legal framework operating at the national level [35]. The Regulation lays the foundational legal basis for China’s systematic and distinctive EPR model.

(5) Plan for the Implementation of Extended Producer Responsibility [36]:In 2016, China promulgated the Plan for the Implementation of the Extended Producer Responsibility System issued by the State Council, marking an important shift in China’s policy on electronic waste management. For electrical and electronic products, China implements EPR by controlling the entire product lifecycle, requiring manufacturers to adopt eco-design, use recycled materials, and ensure the recoverability and recyclability of products after use. The government encourages enterprises to directly participate in collection and recycling activities by establishing formal collection networks, developing reverse logistics systems, and applying the “Internet+” model to enhance collection efficiency. At the same time, China has refined technical standards, licensing conditions, and the electronic waste treatment fund mechanism based on principles of balanced revenues and expenditures, transparency, and the alignment of legal responsibility with economic incentives, thereby promoting formal recycling and expanding EPR implementation nationwide [37].

4.2. Financial mechanisms

In the EPR model for electronic waste, financial mechanisms play a central role in ensuring sustainability and effective implementation. In China, this mechanism is operationalized through the Electronic Waste Treatment Fund, which has been in effect since 1 July 2012. The Fund is financed by mandatory contributions from manufacturers and importers, calculated on the basis of the output volume and categories of electrical and electronic products placed on the market, thereby directly linking financial obligations to the potential generation of waste. The Fund’s revenues are centrally managed within the state budget, ensuring transparency and unified coordination of financial resources.

With regard to expenditure, the Fund is used to provide subsidies to licensed dismantling and recycling facilities that meet the technical and environmental standards prescribed by the state. Subsidy levels are set at fixed rates for each category of equipment, broadly reflecting actual treatment costs, thereby ensuring a stable financial source for formal recycling activities [38]. This mechanism has contributed to narrowing the cost gap between the formal recycling sector and the informal collection and treatment sector, thereby encouraging recycling enterprises to invest in modern technologies and comply with environmental standards. Through this financial instrument, the State does not directly intervene in collection and treatment activities but indirectly regulates electronic waste flows, redirecting waste streams from the informal sector to controlled treatment systems, thereby enhancing the effectiveness of EPR implementation and reducing secondary pollution.

A comparison with China shows that Viet Nam’s EPR financial mechanism remains fragmented and transitional in nature. Under the Law on Environmental Protection 2020, manufacturers and importers may choose to fulfill their recycling responsibilities either by organizing recycling activities themselves or by making financial contributions to the Vietnam Environmental Protection Fund [39]. However, this system has not yet established a dedicated fund specifically for electronic waste, and financial contribution levels are determined according to fixed rates based on product weight or unit quantity [40], which does not fully reflect differences in treatment costs and environmental risk levels across different product streams. At the same time, the use of EPR funds currently remains largely general in nature and has not yet generated sufficiently strong economic signals to regulate electronic waste flows or promote formal recycling. This situation reveals gaps in the design of EPR financial mechanisms, highlighting the need for further refinement to enhance the effectiveness of EPR implementation in the management of electronic waste.

4.3. Organization of the collection and recycling system

The collection and recycling system for electronic waste under the EPR mechanism in China is organized on the basis of Order No. 551 of the State Council, issued on 25 February 2009 and effective from 1 January 2011 [41].

First, institutional allocation of responsibilities

Pursuant to Article 4 of Order No. 551, the management of recycling and treatment of waste electrical and electronic products is allocated among State Council authorities according to their respective functions as follows:

- The environmental protection authority of the State Council is responsible for organizing the formulation of policies and measures on the recycling and treatment of electronic waste, coordinating implementation, and supervising and managing treatment activities.

- The comprehensive resource management authority, together with the industry and information technology authority, cooperates in the formulation and adjustment of the Catalogue of Waste Electrical and Electronic Products subject to regulatory control.

- The commerce authority of the State Council is responsible for the administration of recycling activities and the circulation of waste electrical and electronic products.

- The financial, industry and commerce, quality supervision, taxation, and customs authorities of the State Council perform management functions within their respective mandates, ensuring the collection, disbursement, and control of activities related to electronic waste treatment.

- At the local level, the environmental protection authorities of provincial-level people’s governments are competent to license, inspect, and supervise compliance by treatment facilities in accordance with Articles 6 and 25 of Order No. 551.

Second, licensing and supervision procedures

Pursuant to Articles 6 and 23–24 of Order No. 551, enterprises engaged in electronic waste treatment must obtain qualification licenses and meet requirements relating to safe dismantling technologies, pollution control, and occupational health and safety. Licensed facilities are required to establish an electronic waste information management system (Article 17 of Order No. 551) and submit quarterly reports on dismantling volumes, material flows, and treatment outcomes. These data are transmitted to the National Information Supervision System, as prescribed in Article 31 of the 2012 Administrative Measures on the Collection and Use of the Electronic Waste Treatment Fund, enabling central authorities to monitor, reconcile, and automatically verify actual treatment volumes against subsidies disbursed from the Waste Electrical and Electronic Products Treatment Fund, thereby ensuring transparency, traceability, and automated reconciliation with subsidy payments.

Third, collection networks and reverse logistics

Pursuant to Articles 5 and 11, 12 of Order No. 551, China implements a multi-channel collection system combined with centralized treatment, under which manufacturers and retailers are required to establish formal collection points integrated with distribution networks, service centers, or commercial areas. The State encourages the application of the “Internet+” model to connect scheduling, tracking, and management of waste collection activities, thereby enhancing effective control and eliminating informal collection channels.

Fourth, treatment capacity and eco-industrial parks

To date, China has licensed 109 facilities for the treatment of waste electrical and electronic equipment across 29 provinces. From 2012 to 2021, treatment capacity increased from 46 million units to 164 million units per year, while the volume of formally recycled equipment rose from 10.1 million units to 87.85 million units [42]. These facilities are organized under the model of electronic waste eco-industrial parks, among which the industrial park in Guiyu (Guangdong Province) is regarded as a prominent example of the transition from manual and informal recycling to a centralized and modern system of dismantling, recycling, material recovery, and secondary waste treatment [43].

4.4. Application of digital technologies, databases, and EPR monitoring

In the context of digital transformation, China regards the application of smart technologies as a core pillar in the management of waste electrical and electronic equipment. The integration of the Internet of Things (IoT), big data, and artificial intelligence has enhanced accuracy, efficiency, and transparency throughout the entire process of collection, dismantling, and recycling. IoT technologies enable intelligent tracking and identification of individual electronic products, thereby establishing a digital management system from the point of waste generation. In parallel, big data analytics support the forecasting of e-waste generation trends, the optimization of recycling routes, and timely policy decision-making by regulatory authorities. In addition, China has promoted green recycling technologies, including automated sorting systems and closed-loop recycling lines, contributing to higher recovery rates of precious metals, reduced secondary pollution, and the development of green supply chains for the electrical and electronic sector. Through the coordinated application of these advanced technologies, China has gradually established an intelligent e-waste management network, serving as a key driving force for the development of the circular economy and sustainable green transition [44].

4.5. Assessment of outcomes and factors contributing to success

China has recorded significant progress in the management of electronic waste through the implementation of EPR combined with a dedicated recycling fund for electrical and electronic equipment. For example, according to recent studies, licensed recycling facilities increased their treatment capacity from approximately 46 million units per year in 2012 to about 164 million units per year in 2021 [45]. During the same period, the volume of e-waste processed by formal recycling facilities rose from approximately 10.1 million units to 87.85 million units [46]. Another positive outcome is that China’s electronic recycling industry created approximately 30,000 green jobs in 2020 [47]. EPR has also contributed to the expansion of collection networks and increased the proportion of e-waste entering compliant treatment streams instead of flowing into the informal sector. The application of a unified licensing regime, technical standards, auditing mechanisms, financial supervision, and the operation of the recycling fund has helped formalize recycling activities and significantly narrow the informal recycling sector, which had previously posed serious environmental risks. As a result, transparency, traceability, and oversight of electronic waste flows have been substantially enhanced. Enterprises have likewise been encouraged to engage more deeply in recycling chains through both financial responsibility and direct collection and recycling obligations.

V. Recommendations for improving Vietnamese legislation based on Chinese experience

5.1. Improving institutions and legal instruments on EPR

Practical experience in electronic waste management in China demonstrates the important role of adopting specialized legal instruments governing electronic waste based on a product life-cycle approach, rather than regulating this waste stream in a fragmented manner within general environmental protection laws. This approach contributes to the establishment of a unified legal framework, thereby enhancing transparency and improving the effectiveness of the implementation of extended producer responsibility.

Based on this experience, Viet Nam may consider improving its legal framework on electronic waste in a more centralized and coherent manner, instead of continuing to regulate the issue in a scattered way through the Law on Environmental Protection 2020, Decree No. 08/2022/ND-CP, and Decree No. 05/2025/ND-CP. One feasible option is to study the promulgation of a dedicated decree on electronic waste management, which would provide a unified legal definition, clearly determine the scope of equipment subject to regulation, and anticipate mechanisms for expanding the product list according to a roadmap that is consistent with rapid technological change.

In addition, this subordinate legal instrument could be designed as a sector-specific vertical legal framework governing the entire life cycle of electrical and electronic products, from collection, transportation, dismantling, and recycling to secondary treatment. The core focus would be to establish a life-cycle-based management principle, under which the responsibility of producers and importers does not end at the point of sale but is extended to the post-consumption stage. From the author’s perspective, the recommendations in this subsection are proposed as orientational suggestions that may be considered in the process of improving the system of subordinate legal documents on EPR.

5.2. Improving financial mechanisms, recycling infrastructure, and digitalization of EPR management

China’s experience demonstrates that the coherent design of financial mechanisms, recycling infrastructure, and data management systems plays a decisive role in ensuring the effectiveness of EPR implementation in electronic waste management. On that basis, further improvement of EPR in Viet Nam should be approached in a focused manner and according to a roadmap that is compatible with institutional capacity and practical conditions.

First, with regard to financial mechanisms, Chinese practice shows that a dedicated fund mechanism functions as an effective economic regulatory instrument, transforming the legal obligations of producers into direct financial resources for formal recycling activities. By comparison, the current EPR financial mechanism in Viet Nam remains fragmented and transitional in nature. On this basis, consideration may be given to designing a separate financial mechanism for electronic waste within the framework of the Viet Nam Environmental Protection Fund, with clearly separated management and well-defined expenditure objectives. At the same time, financial contribution levels should be adjusted according to product groups, so as to better reflect differences in treatment costs and environmental risk levels, rather than applying uniform unit- or weight-based rates. On the expenditure side, a gradual shift from general support mechanisms to payment schemes linked to actual collection and recycling outcomes may be considered an appropriate approach, with a view to creating sufficiently strong economic signals to direct electronic waste flows into the formal recycling system.

Second, with regard to recycling infrastructure, China’s experience shows that investment in industrial-scale dismantling and recycling facilities, regionally distributed, has contributed to the standardization of treatment processes and the reduction of secondary pollution. In contrast, in Viet Nam, electronic waste recycling infrastructure remains insufficient and fragmented, with treatment activities still largely dependent on the informal sector.

From a policy-oriented perspective, the author argues that the development of formal recycling infrastructure should be established as a key pillar in the implementation of EPR for electronic waste. On that basis, at the level of institutionalization, consideration may be given to improving subordinate legal provisions in a manner that creates a legal foundation for the formation of regional clusters of electronic waste treatment facilities, linked to technological and environmental standards. In the initial phase, the implementation of this model should follow a phased approach or pilot mechanism, through forms of state investment support or public–private partnerships (PPP), with the aim of gradually shifting electronic waste treatment activities from the informal sector to a regulated recycling system, while simultaneously creating conditions for the EPR financial mechanism to operate effectively in practice.

Third, with regard to digitalization of management, one of the key factors ensuring the effective implementation of EPR in China is the operation of a nationwide electronic waste data management system, enabling end-to-end tracking from collection to recycling. In Viet Nam, the national EPR information system currently mainly serves the registration and reporting of corporate obligations,[48] and has not yet developed into a comprehensive technological platform or legal framework capable of supporting nationwide waste flow tracking.[49]

From a policy-oriented perspective, the author considers that strengthening digitalization and enhancing data management capacity should be regarded as an essential supporting pillar for effective EPR implementation. On that basis, in the short term, consideration may be given to a phased approach, prioritizing pilot initiatives to establish data interconnectivity between enterprises and relevant state management authorities, such as environmental agencies, customs, and tax authorities. Pilot applications of appropriate digital technologies, such as the Internet of Things, artificial intelligence, or big data analytics, may be viewed as necessary preparatory steps, thereby providing an empirical foundation for research and the gradual institutionalization of detailed regulations on monitoring, transparency, and fraud prevention in EPR implementation at subsequent stages.

5.3. Improving the collection mechanism and the organization of EPR

In the initial phase of EPR implementation, Viet Nam has primarily applied a collective EPR model through the National EPR Council and the mechanism of financial contributions to the Viet Nam Environmental Protection Fund, with obligation levels uniformly determined at the central level. This model offers advantages in terms of feasibility and reduced compliance costs in the early stage; however, from the perspective of implementation, it has not created sufficient legal pressure or economic incentives[50] for enterprises to directly participate in collection activities, resulting in a gap between financial obligations and actual collection effectiveness.

By contrast, in China, since 2021, central authorities have begun piloting a “collection target responsibility” mechanism for individual household appliance manufacturers, requiring them to establish take-back systems based on retail networks and after-sales services, thereby moving closer to an individualized EPR model and differentiating obligations according to enterprise scale and product categories.[51] This approach helps improve actual collection rates while differentiating obligations in line with the scale, product types, and capacities of individual enterprises. From a comparative perspective, the core difference between the two models lies in the degree of linkage between EPR obligations and actual collection activities.

On this basis, Viet Nam may consider adjusting its EPR mechanism according to a phased roadmap, whereby the collective EPR model continues to be maintained as a foundational instrument, while gradually establishing collection target mechanisms for large-scale enterprises or for products with high disposal rates. In parallel, the introduction of economic instruments—such as incentive and binding mechanisms linked to collection performance, tax incentives, or green credit for enterprises investing in collection infrastructure - may be considered as supporting solutions, with a view to gradually transforming EPR from a model centered on the fulfillment of financial obligations into one that entails substantive responsibility for waste streams.

Conclusion

Improving legislation on e-waste management from the EPR perspective in Viet Nam should be regarded as an urgent requirement in the context of the rapidly increasing volume of discarded equipment and the growing pressure to transition toward a circular economy model. China’s experience, characterized by a specialized legal framework, transparent financial mechanisms, and integrated recycling infrastructure, demonstrates the effectiveness of a product life-cycle–based governance model when organized at the national scale, endowed with coercive force, and closely linked to technological innovation. Compared with Viet Nam’s current practice, limitations in infrastructure, data availability, collection mechanisms, and the degree of individualization of responsibility constitute the most significant bottlenecks constraining the effective implementation of EPR. Accordingly, a key objective in the coming period is to enhance the sector-specific nature of the legal framework, modernize management instruments through digitalization and traceability, and establish a formal collection and recycling ecosystem capable of competing with the informal sector. In this way, EPR can evolve from a mere cost-sharing mechanism into a driving force for design innovation, environmental protection, and the development of a genuinely sustainable electronic recycling industry.

REFERENCES

1. Law on Environmental Protection 2020.

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3. Circular Economy Promotion Law of the People’s Republic of China 2008,https://www.greenpolicyplatform.org/sites/default/files/downloads/policy-database/CHINA%29%20Circular%20Economy%20Promotion%20Law%20%282008%29.pdf.

4. Law of the People’s Republic of China on the Prevention and Control of Environmental Pollution Caused by Solid Waste (2020 Revision),https://www.piclub.or.jp/wp-content/uploads/2020/08/V.-Law-of-the-People%E2%80%99s-Republic-of-China-on-the-Prevention-and-Control-of-Environment-Pollution-Caused-by-Solid-Wastes-2020-Revision-English.pdf.

5. Decree No. 08/2022/ND-CP dated 10 January 2022 detailing the implementation of the Law on Environmental Protection 2020.

6. Decree No. 05/2025/ND-CP amending a number of provisions of Decree No. 08/2022/ND-CP.

7. Decision No. 252/QD-BTNMT dated 14 February 2023 of the Minister of Natural Resources and Environment on the establishment of the National EPR Council.

8. Implementation Plan for Extended Producer Responsibility,https://www.gov.cn/zhengce/content/2017-01/03/content_5156043.htm.

9. Cornelis P. Balde, Ruediger Kuehr, Tales Yamamoto, Rosie McDonald, Elena D’Angelo, Shahana Althaf, Garam Bel, Otmar Deubzer, Elena Fernandez-Cubillo, Vanessa Forti, Vanessa Gray, Sunil Herat, Shunichi Honda, Giulia Iattoni, Deepali S. Khetriwal, Vittoria Luda di Cortemiglia, Yuliya Lobuntsova, Innocent Nnorom, Noemie Pralat, Michelle Wagner (2024), The Global E-waste Monitor 2024,https://ewastemonitor.info/wp-content/uploads/2024/12/GEM_2024_EN_11_NOV-web.pdf.

10. World Health Organization (2024), E-waste and Child Health,https://www.who.int/news-room/facts-in-pictures/detail/e-waste-and-child-health.

11. United Nations University / StEP Initiative (2014), Solving the E-Waste Problem (StEP) Initiative White Paper,https://www.step-initiative.org/files/_documents/whitepapers/StEP_WP_One%20Global%20Definition%20of%20E-waste_20140603_amended.pdf, p. 4.

12. Cornelis P. Balde, Ruediger Kuehr, Tales Yamamoto, Rosie McDonald, Elena D’Angelo, Shahana Althaf, Garam Bel, Otmar Deubzer, Elena Fernandez-Cubillo, Vanessa Forti, Vanessa Gray, Sunil Herat, Shunichi Honda, Giulia Iattoni, Deepali S. Khetriwal, Vittoria Luda di Cortemiglia, Yuliya Lobuntsova, Innocent Nnorom, Noemie Pralat, Michelle Wagner (2024), The Global E-waste Monitor 2024,https://api.globalewaste.org/publications/file/297/Global-E-waste-Monitor-2024.pdf.

13. OECD (2016), Extended Producer Responsibility: Updated Guidance for Efficient Waste Management.

14. OECD Publishing, Paris.http://dx.doi.org/10.1787/9789264256385-en.

15. Source Intelligence (2025), What Are the EPR Regulations in the EU?,https://blog.sourceintelligence.com/what-are-the-epr-directives-in-the-eu.

16. Nguyen Thi (2025), Extended Producer Responsibility (EPR) Mechanism in the Implementation of Article 54 of the Law on Environmental Protection 2020, Vietnam Environment Magazine,https://tapchimoitruong.vn/chuyen-muc-3/co-che-trach-nhiem-mo-rong-cua-nha-san-xuat-epr--trong-thuc-hien-dieu-54-luat-bvmt-2020-22918.

17. Marco Compagnoni (2022), Is Extended Producer Responsibility Living Up to Expectations? A Systematic Literature Review Focusing on Electronic Waste,https://www.sciencedirect.com/science/article/abs/pii/S0959652622026907.

18. Sai Preetham Grandhi, Pranav Prashant Dagwar, Deblina Dutta (2024), Policy Pathways to Sustainable E-waste Management: A Global Review,https://www.sciencedirect.com/science/article/pii/S2772416624000743.

19. Nguyen Thi (2025), Extended Producer Responsibility (EPR) Mechanism in the Implementation of Article 54 of the Law on Environmental Protection 2020, Vietnam Environment Magazine,https://tapchimoitruong.vn/chuyen-muc-3/co-che-trach-nhiem-mo-rong-cua-nha-san-xuat-epr--trong-thuc-hien-dieu-54-luat-bvmt-2020-22918.

20. Tu Ngoc Trinh, Cam Ha Trinh (2025), Decree No. 05 Updates Extended Producer Responsibility Regulations in Viet Nam, Tilleke & Gibbins,https://www.tilleke.com/insights/decree-05-updates-extended-producer-responsibility-regulations-in-vietnam/.

21. High-Level 12th Regional 3R and Circular Economy Forum in Asia-Pacific (2025), Achieving Circular Economy for the E-Waste Sector in Viet Nam,https://uncrd.un.org/sites/uncrd.un.org/files/12th3r_cp-viet-nam.pdf.

22. Tran T. Y. A., Nguyen T., Herat S., et al. (2025), Monitoring and Evaluating Producer and Importer Compliance with EPR to Prevent Free-Riding in Developing Countries: The Case of Viet Nam,https://doi.org/10.1007/s43615-025-00703-3.

23. Thuy Truong (2025), How Is E-waste Treated?, VnExpress,https://vnexpress.net/rac-dien-tu-duoc-xu-ly-the-nao-4927079.html.

24. Chi Hieu (2024), A Volunteer Group’s 10-Year Effort to Collect More Than 140 Tons of E-waste, VTC News,https://vtcnews.vn/nhom-tinh-nguyen-vien-10-nam-miet-mai-thu-gom-hon-140-tan-rac-dien-tu-ar886225.html.

25. Tran Huyen (2025), Amending Regulations on Tax and Fee Incentives Related to Environmental Protection, Journal of Economics and Finance,https://tapchikinhtetaichinh.vn/sua-doi-quy-dinh-ve-uu-dai-thue-phi-le-phi-lien-quan-den-bao-ve-moi-truong.html.

26. Weila Li, Varenyam Achal (2020), Environmental and Health Impacts Due to E-waste Disposal in China – A Review,https://doi.org/10.1016/j.scitotenv.2020.139745.

27. Jian Cao, Bo Lu, Yangyang Chen, Tuyet Mai Truong, Guangshu Zhai, Gengui Zhou, Boxin Jiang, Jerald L. Schnoor (2016), Extended Producer Responsibility System in China Improves E-waste Recycling: Government Policies, Enterprise, and Public Awareness,https://doi.org/10.1016/j.rser.2016.04.078.

28. Rong Wang, Yi Deng, Shuyuan Li, Keli Yu, Yi Liu, Min Shang, Jiqin Wang, Jiancheng Shu, Zhi Sun, Mengjun Chen, Qian Liang (2021), Waste Electrical and Electronic Equipment Reutilization in China,https://doi.org/10.3390/su132011433.

29. Huihui Liu, Xiaolin Wu, Desheng Dou, Xu Tang, G. Keong Leong (2018), Determining Recycling Fees and Subsidies in China’s WEEE Disposal Fund with Formal and Informal Sectors,https://doi.org/10.3390/su10092979.

30. Zeldin, Wendy (2009), China: Regulations on Electronic Waste, Global Legal Monitor, Library of Congress,https://www.loc.gov/item/global-legal-monitor/2009-04-24/china-regulations-on-electronic-waste/.

31. Yi Deng, Wenjie Wu, Xihua Zhang, Shuyuan Li, Xiaolong Song, Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades,https://doi.org/10.3390/su162310683.

32. Thu Cuc (2025), EPR Implementation Needs to Be Aligned with Viet Nam’s Conditions, Viet Nam Government Portal,https://baochinhphu.vn/thuc-thi-epr-can-phu-hop-voi-cac-dieu-kien-cua-viet-nam-102250325213917227.htm.

33. Manh Dung (2023), Improving Mechanisms and Solutions for E-waste Treatment, Thien Nhien & Moi Truong Magazine,https://thiennhienmoitruong.vn/hoan-thien-co-che-giai-phap-xu-ly-rac-thai-dien-tu.html.

34. Challenges and Barriers in Implementing Extended Producer Responsibility Policies for Plastic Packaging and Selected Policy Implications from International Experience for Viet Nam.

* PhD, University of Law, Hue University. Email: hans@hul.edu.vn. Accepted for publication on 27 January 2026.

[1] Extended Producer Responsibility

[2] Cornelis P. Baldé, Ruediger Kuehr, Tales Yamamoto, Rosie McDonald, Elena D’Angelo, Shahana Althaf, Garam Bel, Otmar Deubzer, Elena Fernandez-Cubillo, Vanessa Forti, Vanessa Gray, Sunil Herat, Shunichi Honda, Giulia Iattoni, Deepali S. Khetriwal, Vittoria Luda di Cortemiglia, Yuliya Lobuntsova, Innocent Nnorom, Noémie Pralat, Michelle Wagner (2024), The global e-waste monitor 2024, https://ewastemonitor.info/wp-content/uploads/2024/12/GEM_2024_EN_11_NOV-web.pdf, accessed 29 September 2025.

[3] World Health Organization (2024), E-waste and Child Health, https://www.who.int/news-room/facts-in-pictures/detail/e-waste-and-child-health?utml, accessed 29 September 2025.

[4] United Nations University/Step Initiative 2014, Solving the E-Waste Problem (Step) Initiative White Paper, https://www.step-initiative.org/files/_documents/whitepapers/StEP_WP_One%20Global%20Definition%20of%20E-waste_20140603_amended.pdf, p.4

[5] Cornelis P. Baldé, Ruediger Kuehr, Tales Yamamoto, Rosie McDonald, Elena D’Angelo, Shahana Althaf, Garam Bel, Otmar Deubzer, Elena Fernandez-Cubillo, Vanessa Forti, Vanessa Gray, Sunil Herat, Shunichi Honda, Giulia Iattoni, Deepali S.

Khetriwal, Vittoria Luda di Cortemiglia, Yuliya Lobuntsova, Innocent Nnorom, Noémie Pralat, Michelle Wagner (2024), The Globale-Waste Monitor 2024, https://api.globalewaste.org/publications/file/297/Global-E-waste-Monitor-2024.pdf, accessed 29 September 2025.

[6] OECD (2016), Extended Producer Responsibility: Updated Guidance for Efficient Waste Management,

OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256385-en, accessed 29 September 2025.

[7] Source Intelligence (2025), What are the EPR Regulations in the EU?, https://blog.sourceintelligence.com/what-are-the-epr-directives-in-the-eu?utml, accessed 29 September 2025.

[8] Nguyen Thi (2025), Extended Producer Responsibility (EPR) Mechanism in the Implementation of Article 54 of the Law on Environmental Protection 2020, https://tapchimoitruong.vn/chuyen-muc-3/co-che-trach-nhiem-mo-rong-cua-nha-san-xuat-epr--trong-thuc-hien-dieu-54-luat-bvmt-2020-22918?utml, accessed 10 October 2025.

[9] Articles 54 and 55 of the Law on Environmental Protection 2020.

[10] OECD (2016), Extended Producer Responsibility: Updated Guidance for Efficient Waste Management,

OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256385-en, accessed 21 January 2026.

[11] Source Intelligence (2025), What are the EPR Regulations in the EU?, https://blog.sourceintelligence.com/what-are-the-epr-directives-in-the-eu?utml, accessed 21 January 2026.

[12] OECD (2024), Extended Producer Responsibility: Basic facts and key principles, OECD ENVIRONMENT POLICY PAPER NO. 41, https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/04/extended-producer-responsibility_4274765d/67587b0b-en.pdf?utmL, accessed 22 January 2026.

[13] Marco Compagnoni (2022), Is Extended Producer Responsibility living up to expectations? A systematic literature review focusing on electronic waste, https://www.sciencedirect.com/science/article/abs/pii/S0959652622026907?utml, accessed 30 September 2025.

[14] Sai Preetham Grandhi, Pranav Prashant Dagwar, Deblina Dutta (2024), Policy pathways to sustainable E-waste management: A global review, https://www.sciencedirect.com/science/article/pii/S2772416624000743?utml, accessed 30 September 2025.

[15] Nguyen Thi (2025), Extended Producer Responsibility (EPR) Mechanism in the Implementation of Article 54 of the Law on Environmental Protection 2020, https://tapchimoitruong.vn/chuyen-muc-3/co-che-trach-nhiem-mo-rong-cua-nha-san-xuat-epr--trong-thuc-hien-dieu-54-luat-bvmt-2020-22918?utml, accessed 10 October 2025.

[16] Decree No. 08/2022/ND-CP dated 10 January 2022 detailing the implementation of the Law on Environmental Protection 2020.

[17] See Clause 1, Article 77 of Decree No. 08/2022/ND-CP detailing the implementation of the Law on Environmental Protection.

[18] See Point b, Clause 4, Article 77 of Decree No. 08/2022/ND-CP detailing the implementation of the Law on Environmental Protection.

[19] See Article 78 of Decree No. 08/2022/ND-CP detailing the implementation of the Law on Environmental Protection.

[20] See Article 81 of Decree No. 08/2022/ND-CP detailing the implementation of the Law on Environmental Protection.

[21] See Article 80 of Decree No. 08/2022/ND-CP detailing the implementation of the Law on Environmental Protection.

[22] Decision No. 252/QD-BTNMT dated 14 February 2023 of the Minister of Natural Resources and Environment on the establishment of the National EPR Council.

[23] Tu Ngoc Trinh, Cam Ha Trinh (2025), Decree No. 05 Updates Extended Producer Responsibility Regulations in Viet Nam, https://www.tilleke.com/insights/decree-05-updates-extended-producer-responsibility-regulations-in-vietnam/13/?utml, accessed 10 October 2025.

[24] Tu Ngoc Trinh, Cam Ha Trinh (2025), Decree No. 05 Updates Extended Producer Responsibility Regulations in Viet Nam, https://www.tilleke.com/insights/decree-05-updates-extended-producer-responsibility-regulations-in-vietnam/13/?utml, accessed 10 October 2025.

[25] High-Level 12th Regional 3R and Circular Economy Forum in Asia-Pacific (2025), Achieving Circular Economy for

the E-Waste Sector in Viet Nam, https://uncrd.un.org/sites/uncrd.un.org//files/12th3r_cp-viet-nam.pdf?utml, truaccessed 12 October 2025.

[26] Tran, T.Y.A.; Nguyen, T.; Herat, S.; et al. (2025), Monitoring and Evaluating Producer and Importer Compliance with Extended Producer Responsibility to Prevent Free-Riding in Developing Countries: The Case of Viet Nam, Circular Economy and Sustainability, https://doi.org/10.1007/s43615-025-00703-3, accessed 10 October 2025.

[27] Thuy Truong (2025), How Is E-Waste Treated?, VnExpress, https://vnexpress.net/rac-dien-tu-duoc-xu-ly-the-nao-4927079.html, accessed 13 October 2025.

[28] Chi Hieu (2024), Volunteer Group Collects More Than 140 Tons of E-Waste Over 10 Years, VTC News, https://vtcnews.vn/nhom-tinh-nguyen-vien-10-nam-miet-mai-thu-gom-hon-140-tan-rac-dien-tu-ar886225.html, accessed 12 October 2025.

[29] Tran Huyen (2025), Amendments to Regulations on Tax, Fee and Charge Incentives Related to Environmental Protection, Tap chi Kinh te Tai chinh, https://tapchikinhtetaichinh.vn/sua-doi-quy-dinh-ve-uu-dai-thue-phi-le-phi-lien-quan-den-bao-ve-moi-truong.html, accessed 30 September 2025.

[30] Weila Li, Varenyam Achal (2020), Environmental and health impacts due to e-waste disposal in China – A review, https://doi.org/10.1016/j.scitotenv.2020.139745, accessed 30 September 2025.

[31]Jian Cao, Bo Lu, Yangyang Chen, Tuyet Mai Truong, Quang Thuc Zhai, Gengui Zhou, Boxin Jiang, ,Jerald L. Schnoor (2016), Extended producer responsibility system in China improves e-waste recycling: Government policies, enterprise, and public awareness, https://doi.org/10.1016/j.rser.2016.04.078, accessed 30 December 2025.

[32] See "Law on the Promotion of Cleaner Production 2002" at https://english.mee.gov.cn/Resources/laws/envir_elatedlaws/200710/t20071009_109966.shtml, accessed 12 October 2025.

[33] See "Circular Economy Promotion Law 2008" at https://www.greenpolicyplatform.org/sites/default/files/downloads/policy-database/CHINA%29%20Circular%20Economy%20Promotion%20Law%20%282008%29.pdf, accessed 12 October 2025.

[34] See "Law on the Prevention and Control of Environmental Pollution by Solid Waste (2020 Revision)" at https://www.piclub.or.jp/wp-content/uploads/2020/08/V.-Law-of-the-People%E2%80%99s-Republic-of-China-on-the-Prevention-and-Control-of-Environment-Pollution-Caused-by-Solid-Wastes-2020-Revision-English.pdf, accessed 13 October 2025.

[35] Rong Wang, Yi Deng, Shuyuan Li, Keli Yu, Yi Liu, Min Shang, Jiqin Wang, Jiancheng Shu, Zhi Sun, Mengjun Chen và Qian Liang (2021), Waste Electrical and Electronic Equipment Reutilization in China, https://doi.org/10.3390/su132011433, accessed 13 October 2025.

[36] See "Plan for the Implementation of the Extended Producer Responsibility System" at https://www.gov.cn/zhengce/content/2017-01/03/content_5156043.htm, accessed 14 October 2025.

[37] See Point (a), Section III of the Plan for the Implementation of the Extended Producer Responsibility System, https://www.gov.cn/zhengce/content/2017-01/03/content_5156043.htm, accessed 14 October 2025.

[38] Huihui Liu, Xiaolin Wu, Desheng Dou, Xu Tang, G. Keong Leong (2018), Determining Recycling Fees and Subsidies in China’s WEEE Disposal Fund with Formal and Informal Sectors, https://doi.org/10.3390/su10092979, accessed 30 December 2025.

[39] Clause 2, Article 54 of the Law on Environmental Protection 2020.

[40] Point (a), Clause 4, Article 54 of the Law on Environmental Protection 2020.

[41] Zeldin, Wendy (2009), China: Regulations on Electronic Waste, https://www.loc.gov/item/global-legal-monitor/2009-04-24/china-regulations-on-electronic-waste/?utml, accessed 14 October 2025.

[42] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 14 October 2025.

[43] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, taccessed 14 October 2025.

[44] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 14 October 2025.

[45] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 14 October 2025.

[46] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 14 October 2025.

[47] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 14 October 2025.

[48] Thu Cuc (2025), EPR Implementation Needs to Be Consistent with Viet Nam’s Conditions, https://baochinhphu.vn/thuc-thi-epr-can-phu-hop-voi-cac-dieu-kien-cua-viet-nam-102250325213917227.htm?utml, accessed 15 October 2025.

[49] Manh Dung (2023), Improving Mechanisms and Solutions for E-Waste Treatment, https://thiennhienmoitruong.vn/hoan-thien-co-che-giai-phap-xu-ly-rac-thai-dien-tu.html, accessed 15 October 2025.

[50] Trinh Thi Minh Chau; Nguyen Thi Huyen Trang (2025), Challenges and Barriers in Implementing Extended Producer Responsibility Policies for Plastic Packaging and Policy Implications from International Experience for Viet Nam, https://tcnnld.vn/news/detail/69502/Thach-thuc-rao-can-khi-thuc-hien-chinh-sach-trach-nhiem-mo-rong-cua-nha-san-xuat-doi-voi-bao-bi-nhua-va-mot-so-giai-phap-goi-mo-tu-kinh-nghiem-the-gioi-cho-Viet-Nam.html?utml, accessed 22 January 2026.

[51] Yi Deng, WenjieWu, Xihua Zhang, Shuyuan Li, Xiaolong Song and Jingwei Wang (2024), Overview of China’s Waste Electrical and Electronic Equipment Recycling in the Last Two Decades, https://doi.org/10.3390/su162310683, accessed 15 October 2025.