ENVIRONMENTAL LEGAL ROADMAP 2025–2032

The period 2025–2032 brings major changes to environmental law: most national technical regulations (QCVN) on discharge have been reissued, the new Law on Construction is in force, and the monitoring thresholds and permitting procedures have been adjusted. For an operating plant, the new discharge standards become mandatory mainly from 1 January 2032, but several obligations already apply or are about to fall due: wastewater fees, greenhouse gas inventories, packaging recycling responsibility, and noise and vibration from 1 January 2027. Every investment decision from now on should take these milestones into account, so that you do not have to invest twice.

This article sets out the milestones that directly affect factories, farms, and industrial parks and clusters, updated to October 2026, together with what to do at each milestone.

Summary in one minute

Read by sector

If you only have 5 minutes: read section 1 to see the whole timeline, then section 10 to check your own plant.

1. The full roadmap, 2025–2033

The BAT milestones are deadlines of the form “before this date”. Provincial People’s Committees may issue a roadmap for applying QCVN 19:2024 earlier than 2032.

2. Industrial wastewater: QCVN 40:2025

Circular 06/2025/TT-BTNMT, signed on 28 February 2025, effective from 1 September 2025. Dedicated article: QCVN 40:2025 industrial wastewater.

What this regulation replaces

QCVN 40:2025/BTNMT replaces QCVN 40:2011/BTNMT and merges the previous sector-specific regulations into one common regulation. Plants in the sectors below no longer have a regulation of their own:

• Seafood processing (QCVN 11-MT:2015), paper and pulp (QCVN 12-MT:2015), textile dyeing (QCVN 13-MT:2015), steel production (QCVN 52:2017);
• Natural rubber primary processing (QCVN 01-MT:2015), fuel alcohol production (QCVN 60-MT:2015), cassava starch processing (QCVN 63:2017);
• Medical wastewater (QCVN 28:2010), solid waste landfills (QCVN 25:2009), petrol depots and filling stations (QCVN 29:2010).

It does not apply to livestock wastewater, domestic wastewater, urban and concentrated residential area wastewater, or water extracted from offshore oil and gas facilities (see section 3).

Application timeline

Three important technical changes

1. Three receiving water body levels: Column A, B, C (replacing the two columns A and B). Column A: discharge to a water body used for domestic water supply, or managed under level A of QCVN 08:2023/BTNMT, or as set by the provincial People’s Committee; Column B: a water body managed for improving water environment quality, or as set by the provincial People’s Committee; Column C: all other cases. Where no zoning has been made, Column B applies.
2. Limits depend on discharge flow rate F: split into two groups, F ≤ 2,000 m³/day and F > 2,000 m³/day; the larger the plant’s discharge, the stricter the limits. The new regulation no longer uses the Kq and Kf multiplication factors of QCVN 40:2011.
3. TOC may be measured instead of COD, with its own limit values for TOC.

Main limits under QCVN 40:2025 (mg/L)

Discharge flow rate F ≤ 2,000 m³/day

Discharge flow rate F > 2,000 m³/day

Excerpt from Table 1, QCVN 40:2025/BTNMT. For other parameters (pH, total N, total P, ammonium, metals, coliform, etc.) see Table 2 of the regulation.

Comparison with the old standard: not every parameter is stricter

Column B, unit mg/L; F is the discharge flow rate (m³/day); the old standard is the C value of QCVN 40:2011.

Under QCVN 40:2011, a plant’s actual limit is the C value multiplied by the receiving water body factor Kq (0.6–1.3) and the flow rate factor Kf (0.9–1.2). So the actual degree of tightening differs between plants and must be calculated case by case. COD is usually the parameter that decides which treatment stage has to be added.

Plants inside industrial parks and clusters

A plant connected to a centralised treatment system must meet the connection requirements of the infrastructure investor, not QCVN 40:2025 directly. However, the centralised treatment plant of the industrial park or cluster must meet QCVN 40:2025 at the final discharge point (a plant that was already operating before 1 September 2025 may use the old regulation until the end of 31 December 2031). When the effluent standard is tightened, the infrastructure investor may adjust the connection requirements or the treatment fees charged to secondary enterprises. It is advisable to talk early with the park management board about its plans. See also wastewater treatment for industrial parks and clusters.

What to do from now

1. Identify the plant’s column and flow rate: whether the receiving water body falls under Column A, B or C (if not yet zoned, Column B applies); the actual discharge flow rate and the flow rate in the permit.
2. Compare the last 12 months of monitoring results with the new limits, parameter by parameter, including the parameters in Table 2 of the regulation.
3. Assess the existing treatment plant: spare capacity, which stages can be upgraded, which must be added. Many plants can improve effluent quality through operational optimisation before having to invest in more equipment.
4. Build it into the investment plan: expansion and capacity-increase projects must apply QCVN 40:2025 as soon as the environmental dossier is prepared; other renovations before 2032 should also be designed to the new standard.
5. Budget along the roadmap for 2027–2031 rather than concentrating spending in the last years before the deadline.

3. Domestic wastewater, livestock wastewater and wastewater fees

QCVN 14:2025: plants with their own domestic wastewater treatment system

The new regulation on domestic and urban wastewater (Circular 05/2025/TT-BTNMT), effective 1 September 2025, replaces QCVN 14:2008. Under item 4.9, a plant’s domestic wastewater that is collected and treated separately from industrial wastewater is subject to QCVN 14:2025. Existing facilities may use the old regulation until the end of 31 December 2031 and must meet the new regulation from 1 January 2032. The new regulation adds COD (or TOC), total nitrogen and total phosphorus.

Excerpt from Table 2, QCVN 14:2025/BTNMT (domestic wastewater of investment projects and facilities). Plants in industrial parks and clusters connected to a centralised plant follow the requirements of the infrastructure investor.

QCVN 62:2025: livestock wastewater

Circular 04/2025/TT-BTNMT, effective 1 September 2025, replaces QCVN 62-MT:2016. Operating farms may use the old regulation until the end of 31 December 2031 and must meet the new regulation from 1 January 2032. Domestic wastewater combined with livestock wastewater is managed as livestock wastewater; livestock wastewater combined with industrial wastewater is subject to QCVN 40:2025. Livestock farming is also on the list that must apply best available techniques (section 9).

Environmental protection fee on industrial wastewater (from 1 January 2026)

• Decree 346/2025/ND-CP replaces Decree 53/2020/ND-CP. The fee is paid quarterly, at the latest on the 20th of the first month of the following quarter; the facility determines the amount payable itself.
• A facility that is not subject to wastewater monitoring and does not self-monitor to calculate the fee: the fee is calculated by flow rate, at VND 1,700/m³ (if it self-monitors once a year, it is calculated by pollutant load). A facility subject to monitoring: calculated by the load of each pollutant (COD, TSS, heavy metals, etc.).
• Production wastewater that is reused as prescribed is exempt from the fee: reusing water reduces both the cost of supply water and the wastewater fee.

4. Emissions to air, noise and vibration

QCVN 19:2024: one common emission regulation

Circular 45/2024/TT-BTNMT, effective 1 July 2025. QCVN 19:2024/BTNMT replaces the industrial emission regulations QCVN 19:2009, 20:2009 (organic substances), 21:2009 (chemical fertiliser), 22:2009 (thermal power), 23:2009 (cement), 34:2010 (petrochemical refining), 51:2017 (steel), and replaces the emission limit tables in the regulations on incinerators, co-processing of waste in cement kilns, and waste oil recycling.

The limits are set separately by type of equipment, fuel and capacity, converted to a reference oxygen content, and by zone: Column A (strict protection), B (limited emissions), C (all others); where no zoning has been made, Column B applies.

Example: coal-fired boilers of 20 tonnes of steam/hour or more

Unit mg/Nm³, converted to 6% O₂; the old standard is the C value, Column B of QCVN 19:2009, and the new standard is QCVN 19:2024 by Column A, B, C.

NOx is expressed as NO₂. The C value of QCVN 19:2009 has not been multiplied by the flow rate factor Kp and the zone factor Kv, and is not converted to a reference oxygen content as in QCVN 19:2024; it is shown only to illustrate the scale of the change. Boilers below 20 tonnes of steam/hour and boilers using oil or biomass have separate limit lines in the regulation (see the section below).

Waste incinerators: QCVN 30:2025

QCVN 30:2025/BNNMT (Circular 45/2025/TT-BNNMT, effective 9 February 2026) is a dedicated regulation for waste incinerators, replacing QCVN 02:2012 (medical solid waste incinerators), QCVN 30:2012 (industrial waste incinerators) and QCVN 61-MT:2016 (domestic solid waste incinerators). The regulation also applies to plants that incinerate their own waste, not only to waste treatment contractors. A plant with an incinerator should check the limits and the transition roadmap in the original text of the Circular.

The environmental protection fee on emissions is collected under Decree 153/2024/ND-CP, from 5 January 2025; who must pay and the fee rates should be checked against the original text of the Decree.

Noise and vibration: the nearest milestone is 1 January 2027

QCVN 26:2025 (noise) and QCVN 27:2025 (vibration), issued with Circular 01/2025/TT-BNNMT, replace QCVN 26:2010 and 27:2010. New projects apply them from 14 November 2025. Operating facilities may use the old regulation until the end of 31 December 2026 and must meet the new regulation from 1 January 2027. A plant with large air compressors, generators, cooling towers or exhaust fans near residential areas should hire a qualified monitoring unit to re-measure against the new regulation before this milestone.

5. Automatic monitoring of wastewater and emissions, and source water monitoring

When automatic, continuous wastewater monitoring must be installed

Decree 08/2022/ND-CP Article 97 and Appendix XXVIII, as amended by Decree 48/2026/ND-CP (effective 29 January 2026). The flow rate is counted by the total design capacity stated in the environmental permit, not by the actual discharge.

• Notable change: before 29 January 2026, every industrial park and cluster discharging wastewater into the environment had to monitor automatically; now it is mandatory only from 500 m³/day. For parks and clusters discharging 200 to below 500 m³/day: the Decree lets them choose automatic or periodic monitoring, but it is advisable to ask the provincial Department of Agriculture and Environment to agree on the form before investing, because Law 146/2025/QH15 amends the monitoring provisions for industrial parks and clusters.
• Parameters: inlet and outlet flow rate, pH, temperature, TSS, COD or TOC, ammonium (ammonium is dropped if the sector’s regulation does not control it). The system has a camera and an automatic sampler, and transmits data to the Department. New projects must install it before trial operation.
• Periodic monitoring: every 3 months for projects subject to environmental impact assessment, every 6 months for the remaining cases. Facilities that have installed and maintain automatic monitoring are exempt from periodic monitoring, in full or only for the parameters monitored automatically, depending on the flow rate group (Article 97).
• Exemption from periodic monitoring after 3 years of compliance: the main parameters have been monitored automatically and continuously and met the regulation for 3 consecutive years, and the most recent inspection (with wastewater sampling that met the regulation) found no violation on wastewater discharge; send a written notice in the prescribed form to the agency that issued the environmental permit. Meeting the regulation through periodic monitoring does not fall under this case.
• Not covered: facilities connected to a centralised wastewater treatment system, aquaculture facilities and some special cases.
• Operating infrastructure: a wastewater treatment system discharging from 50 m³/day of a type with a risk of causing pollution must have an independent electricity meter, an outlet flow meter and an operating log kept for 2 years.
• Localities may set stricter rules: for example, Hanoi has its own resolution applying lower thresholds than the general level for some types of operation. Check the regulations of the province where the plant is located.

When automatic, continuous emission monitoring must be installed

Decree 08/2022/ND-CP Article 98 and Appendix XXIX (amended by Decree 05/2025/ND-CP). The threshold is counted by the design flow rate or capacity of the dust and emission treatment works and equipment stated in the environmental permit, adding up works and equipment of the same type.

A summary table of the main groups; for the full list by type of equipment (including recycling and waste treatment facilities and lead recycling) see Appendix XXIX.

• Deadline: facilities in the mandatory group had to finish installation and transmit data to the Department by 31 December 2024 at the latest (the deadline has passed); from 1 January 2025, new projects in this group must install before trial operation. For the optional group, the Government will decide the date from which installation becomes mandatory, period by period.
• A plant not on Appendix II whose total flow rate from all dust and emission sources (boilers, incinerators, kilns, including other stacks and vents) is 50,000 m³/hour or more: only needs periodic monitoring.
• Automatic parameters depend on the type of equipment, and usually include flow rate, pressure, temperature, O₂, dust, SO₂, NOx and CO; the system has a monitoring camera.
• Periodic emission monitoring (continuously operating facilities): for those subject to environmental impact assessment, every 3 months (heavy metals and organic substances every 6 months; dioxin/furan once a year); in other cases every 6 months (heavy metals, organic substances, dioxin/furan once a year). The specific parameters are stated in the environmental permit.
• Exemption from periodic emission monitoring: the optional group is exempt once it has installed automatic monitoring; the mandatory group is exempt only for the parameters monitored automatically. In addition, exemption applies once the main parameters have been monitored automatically and continuously and met the regulation for 3 consecutive years, and the most recent inspection (with dust and emission sampling that met the regulation) found no violation of discharge above the regulation; send a written notice in the prescribed form to the agency that issued the environmental permit.
• Quick check: look at the design flow rate of the emission treatment system in the environmental permit; for a plant on Appendix II, add up furnaces and equipment of the same type; for other plants, add up all discharge sources; then compare with the table above.

Water supply projects drawing surface water: source water quality monitoring

Law on Water Resources 2023; Decree 53/2024/ND-CP, as amended by Decree 23/2026/ND-CP.

• Abstracting surface water of 10,000 m³/day or more to produce and supply clean water for domestic use: online monitoring at the intake point is mandatory, at least temperature, pH, DO, TSS, COD, ammonium and the other parameters stated in the permit; at a frequency of no more than once per hour, transmitted to the national water resources information system.
• Works built before 1 July 2024 must complete installation before 1 July 2026 (the deadline has passed).
• When online data is interrupted due to maintenance, calibration or equipment repair: monitor once every 3 days, with a remediation period of no more than 60 days; a transmission line interrupted for more than 72 hours must be reported in writing.
• Clean water suppliers below 10,000 m³/day: online water quality monitoring is encouraged.
• A plant that abstracts surface water itself for production: water quality is monitored according to the abstraction permit; the volume abstracted must be updated daily (online flow measurement is encouraged).
• Surface water abstraction for production (non-agricultural) of 100 m³/day or less: no registration and no abstraction permit required.

6. Construction investment: the new Law on Construction

Law on Construction No. 135/2025/QH15 and Decree 217/2026/ND-CP, effective from 1 July 2026, replace the 2014 Law on Construction and Decree 175/2024/ND-CP. Only the provisions on construction permit exemption and notice of commencement (clauses 2 and 3 of Article 43) apply from 1 January 2026.

What to do

1. For projects of up to VND 40 billion: prepare an economic and technical report, shortening procedures and preparation time.
2. Determine the grade of the treatment plant works from the project preparation stage, to know whether the feasibility study report must be appraised and whether a permit exemption applies.
3. For works inside industrial parks: prepare the permit dossier at the park management board in parallel with the environmental dossier.

7. Environmental permits, periodic reports, industrial clusters

Resolution 66.19/2026/NQ-CP of 18 May 2026, applying until the end of 28 February 2027 (or earlier if a replacement document is issued). See also the article Decree 48/2026: who no longer needs an environmental permit and NGO’s environmental permit service.

Who must hold an environmental permit while Resolution 66.19 applies

Below the thresholds above, only an environmental registration is needed: at the provincial People’s Committee if wastewater requiring treatment is 50 m³/day or more or dust and emissions are 20,000 m³/hour or more; at the commune-level People’s Committee in the remaining cases (except exempt cases). Even where no permit is needed, wastewater and emissions must still meet the regulations.

Who issues the permit and the procedural changes

• The Chairman of the provincial People’s Committee issues permits for most subjects. The Ministry of Agriculture and Environment: hazardous waste recycling and treatment facilities operating in 2 or more provinces; scrap importing facilities. The Ministry of National Defence and the Ministry of Public Security: projects and facilities covered by state secrets on national defence and security.
• The procedure for exchange of a permit has been abolished (Law 146/2025/QH15, Decree 48/2026/ND-CP): renaming the project or facility or a change of owner only needs to be updated in the periodic environmental protection work report.
• Reissuance of permits is not carried out while Resolution 66.19 applies; a plant whose permit is about to expire in this period should ask the licensing agency early how it will be handled. Some procedures in the Resolution have their own application dates; pending dossiers should be checked against the guidance in Official Letter 7046/BNNMT-MT.
• Adding a plan for reuse, transfer or receipt of wastewater is a case that requires the permit to be adjusted.

Environmental protection work reports, hazardous waste

The annual report (period from 1 January to 31 December) is submitted before 15 January of the following year; infrastructure investors of industrial parks and clusters submit before 20 January. It may be submitted electronically. Hazardous waste may be stored at the facility for no more than 1 year from when it arises; if the period is exceeded because no suitable treatment unit has been found, an annual report must be made.

From 9 February 2026, determining whether a waste is hazardous follows QCVN 07:2025/BNNMT (Circular 44/2025/TT-BNNMT), which replaces QCVN 07:2009/BTNMT and QCVN 50:2013/BTNMT (hazardous thresholds for sludge from water treatment processes). A plant with wastewater treatment plant sludge, boiler ash and slag, or chemical residue should review its classification results against the new regulation when signing collection and treatment contracts.

Industrial clusters not required to build a centralised wastewater treatment plant

From 29 January 2026, an industrial cluster is not required to build a centralised wastewater collection and treatment system if its secondary facilities already have adequate treatment systems of their own and it falls under one of two cases: the cluster was operating before 1 January 2022 and is more than 80% occupied; or the total wastewater flow of the cluster (including secondary facilities) is below 100 m³/day.

8. Greenhouse gases, the carbon market and CBAM

Decision 42/2026/QD-TTg of 10 August 2026 · Decree 06/2022/ND-CP (amended by Decrees 119/2025/ND-CP and 83/2026/ND-CP) · Decision 232/QD-TTg of 24 January 2025.

New list: 2,441 facilities required to carry out greenhouse gas inventories (effective 25 September 2026)

An increase of 275 facilities over the 2024 list (Decision 13/2024/QD-TTg). The list is reviewed and updated every 2 years: a plant not named this time may still be named at the next update after expanding production.

Obligations of facilities on the list

• Facility-level greenhouse gas inventory every two years, sent to the provincial People’s Committee before 31 March (under the old list, the first period was in 2025 for 2024 data; on this cycle, the next period is expected before 31 March 2027). Thermal power, steel and cement plants that are allocated quotas have their own reporting schedule; a facility newly added to the list should ask the provincial Department of Agriculture and Environment to confirm its first reporting period.
• Emission mitigation plan for 2026–2030 (under the old list, the deadline for preparing it was 31 December 2025; a facility newly added to the list should ask the Department about the deadline that applies to it).
• Annual facility-level emission mitigation report, before 31 March, starting in 2027. This is a different report from the inventory report.

Why management should care

• The domestic carbon market (Decision 232/QD-TTg): pilot from 06/2025 to the end of 2028, formally operating from 2029. Emission quotas are allocated to the facilities on the inventory list; quotas for 2025–2026 have been allocated to 110 thermal power, steel and cement plants, and quotas for 2027–2028 are to be allocated before 31 October 2027. When the market operates, a facility emitting above its quota can buy additional quotas or carbon credits to offset, or invest in reducing emissions.
• Enterprises exporting to the EU (CBAM): from 1 January 2026, the EU Carbon Border Adjustment Mechanism enters its definitive period for iron and steel, aluminium, cement, fertiliser, electricity and hydrogen. EU importers (above the exemption threshold of 50 tonnes per year, which does not apply to electricity and hydrogen) buy CBAM certificates from 1 February 2027 for goods imported from 2026, and will ask Vietnamese suppliers to provide verified emission data.
• Customers with foreign direct investment (FDI) and supply chains increasingly ask for emission data in supplier assessments.

What to do

1. Check the plant’s name in the appendix of Decision 42/2026/QD-TTg.
2. Assign a focal person and standardise monthly data: electricity consumed, fuel (coal, oil, gas), raw materials, waste.
3. Prepare the inventory report and the mitigation plan following the guidance of the sector’s managing ministry (see the facility-level greenhouse gas inventory procedure and NGO’s inventory and emission reduction services).
4. Look for low-cost emission reductions: in a wastewater treatment plant there are usually two significant sources, the electricity for the air blowers and the methane from the anaerobic tank and biogas lagoon.

9. Best available techniques (BAT), packaging recycling, plastics

Best available techniques: apply to at least one production stage

Law on Environmental Protection Article 105; Decree 08/2022/ND-CP Article 53 and Appendix II (replaced by Decree 48/2026/ND-CP).

Each type has its own capacity threshold in Appendix II; some small-scale types are not on the list. The list above is a summary and must be checked against the original text.

Recycling responsibility of producers and importers (EPR): Decree 110/2026, effective 25 May 2026

• Applies to the packaging of food, cosmetics, medicines, fertiliser, animal feed, veterinary medicines, detergents, cement and other product groups (batteries, accumulators, lubricating oil, tyres and tubes, electrical and electronic products, etc.). Revenue from these products below VND 30 billion per year is exempt from the packaging recycling obligation.
• Some mandatory recycling rates: paper and carton packaging 20%; rigid PET 22%; rigid HDPE, LDPE, PP, PS 15%; flexible plastic 10%; aluminium 22%; glass 15%.
• Each year, choose one of two ways: organise recycling yourself, then register the plan and report results before 1 April; or make a financial contribution to the Vietnam Environment Protection Fund, then declare before 1 April and pay before 20 April. Recycling rates rise for the first time in 2029 (each increase no more than 10%, on a 3-year cycle).

Plastics

• From 1 January 2026: no production or import of hard-to-biodegrade plastic bags smaller than 50 × 50 cm and with a single-layer film thickness of less than 50 µm (except for export goods and bags used to package goods being sold).
• After 31 December 2030: production and import stop for single-use plastic products, hard-to-biodegrade plastic packaging and products containing microplastics. Main exceptions: production for export; packaging used to package products and goods sold on the market; products with the Vietnam eco-label.

10. Self-check table and year-by-year plan

A 15-minute self-check

Suggested plan by year

Main legal bases

• Law on Environmental Protection 2020, amended by Law No. 146/2025/QH15;
• Decree 08/2022/ND-CP, amended by Decrees 05/2025/ND-CP, 48/2026/ND-CP and 110/2026/ND-CP (Consolidated Document 49/VBHN-BNNMT); Circular 02/2022/TT-BTNMT (as amended);
• Circulars 06/2025/TT-BTNMT (QCVN 40:2025), 05/2025/TT-BTNMT (QCVN 14:2025), 04/2025/TT-BTNMT (QCVN 62:2025), 45/2024/TT-BTNMT (QCVN 19:2024), 01/2025/TT-BNNMT (QCVN 26 and 27:2025), 44/2025/TT-BNNMT (QCVN 07:2025), 45/2025/TT-BNNMT (QCVN 30:2025);
• Decree 346/2025/ND-CP on environmental protection fees on wastewater; Decree 153/2024/ND-CP on environmental protection fees on emissions; Resolution 66.19/2026/NQ-CP;
• Law on Construction No. 135/2025/QH15, Decree 217/2026/ND-CP;
• Law on Water Resources 2023, Decree 53/2024/ND-CP amended by Decree 23/2026/ND-CP;
• Decision 42/2026/QD-TTg; Decree 06/2022/ND-CP amended by Decrees 119/2025/ND-CP and 83/2026/ND-CP; Decision 232/QD-TTg;
• Regulation (EU) 2023/956 on CBAM, amended by Regulation (EU) 2025/2083.

A summary of the legal documents in force up to October 2026, for reference. The Government has submitted to the National Assembly a draft amended Law on Environmental Protection (Submission 701/TTr-CP of 17 September 2026); when the new law is passed, some content may change. When preparing dossiers, check the original text of the documents.