2024 – Southeast Asia’s year of recycling?
Introduction
Markets in Southeast Asia are among the worst victims and the worst perpetrators when it comes to marine plastic waste and plastic pollution. Half of the world’s top ten contributors of marine plastic waste are ASEAN member states; more than half of the waste generated in ASEAN markets is uncollected and less than a quarter is recycled.
In recognition of the need for a coordinated regional effort, ASEAN launched the Regional Action Plan for Combating Marine Debris in ASEAN Member States (2021 – 2025) (RAP) in 2021, outlining the current status, challenges and potential solutions around plastic consumption, waste management and marine debris pollution in the region. 14 priority actions were identified, including the need to strengthen policies, build capacity and raise public awareness, as well as engage the private sector. However, at the national level, progress has been uneven.
From January 1, 2024, new legislation came into effect in Vietnam that aims to address packaging waste. Vietnam follows the Philippines with rules on ‘Extended Producer Responsibility’ (EPR), a policy concept that shifts operational and/or financial responsibility for waste management on to market operators.
Vietnam and the Philippines are frontrunners in the region, though several other Southeast Asian markets have pilot or voluntary schemes in place or are in the process of drafting domestic law to set up an EPR framework.
EPR policies have been proliferating worldwide, supported at the highest policy level by the UN Sustainable Development Goals. EPR-type policies have been driven furthest in the European Union, where they apply to a range of products including batteries, waste electronics, and packaging, with rules for textiles under consideration. Four US states have passed EPR bills for packaging and a further 11 states proposed EPR legislation in 2023. There are at least 200 EPR programmes in Canada at the provincial level – a mixture of voluntary and mandatory schemes, covering 30 categories of materials; the federal government published a Canada-wide Action Plan for EPR to help harmonise the various schemes. There are also similar rules in India, Chile, Colombia, and South Africa.
What are EPR policies?
Extended Producer Responsibility (EPR) is “a concept where producers… of products bear a significant degree of responsibility for the environmental impacts of their products throughout the product life cycle, including upstream… and downstream impacts”.1
EPR policies aim to shift responsibility from governments to economic operators in the value chain, including manufacturers, importers, distributers, and retailers. This responsibility can be both physical and financial. 2
When aligned with circularity principles, EPR policies incentivise manufacturers to design products that have a lower environmental impact as well as requiring them to facilitate the collection and treatment of waste products.3 Effective EPR policies should encourage practices nearer the top of the waste hierarchy – reducing the amount of waste generated, encouraging re-use, and improving recycling and recovery; avoiding disposal, especially into the environment.
EPR policy can be hard to get right, given the complexity and number of variables in a particular market. For example, plastic waste problems can be driven by a range of factors, from consumer culture, business practices, infrastructure availability, public services provision, and political and administrative challenges at different levels of government. For EPR policies to work, they must be sculpted to fit the national context, as well as being flexible enough to apply in the diversity of situations within a single market – consider the different approaches that are required for rural mountain communities and inner-city suburbs.
For schemes to work effectively they may require access to both high quality recycling plastic content and recycling facilities, both of which are currently uncommon in Southeast Asia. The integration of existing schemes and value chains at the local government level and by the informal sector, must also be considered.
It is essential that EPR schemes are implementable and enforceable for them to achieve their stated policy objectives. The following are common tools used in EPR policies:
- Design requirements for products that use less material and/or are easily reusable or recyclable. This can be implemented and enforced by minimum recycled content and responsible raw materials sourcing requirements, as well as performance and durability requirements.
- Encouraging or mandating producers to establish and/or fund waste collection and recycling systems such as take-back programmes or work with Producer Responsibility Organisations (PROs) alongside other market operators to manage waste.
- Reporting systems to gather data on packaging and materials in the supply chain. This can be implemented by collection targets and traceability requirements.
Governments also have a broader suite of policy levers that may complement core EPR policy, including public information campaigns to encourage small businesses and consumers to ensure their waste enters the waste management system and investing in better public waste collection provisions.
Southeast Asia progress snapshot
- Frontrunners in Southeast Asia
Frontrunners in Southeast Asia include the Philippines and Vietnam, both of which passed EPR legislation in 2022 that is now in effect. However, teething problems are common and a constant dialogue between the government and stakeholders in the plastics supply chain is necessary.
Philippines
The Philippines passed the Republic Act No.11898 Extended Producer Responsibility Act in July 2022, requiring large-scale companies to establish a mechanism for the recovery of their plastic packaging, with a target of 80% by 2027. Implementing rules and regulations were signed in January 2023, yet only 17% of the 4000 possible companies had registered by November 2023.4
A recent assessment by government think-tank, the Philippines Institute for Development Studies (PIDS), identified a number of areas where further clarity is needed to improve the implementation and enforcement of the mandatory EPR programme. The report also identified gaps in the scheme including a lack of recycling targets and re-design guidance.5
Overall, it would be premature to assess the impact of the EPR Act given the early stage of implementation. However, improved participation, as well as maintaining open dialogue between the government and operators to gather feedback and improve guidance would help combat plastic pollution more effectively.
Vietnam
Vietnam has set some of the most ambitious targets in the region including the objective to use 100% environmentally friendly packaging by 2025, in shopping malls and supermarkets. To achieve this, the Law on Environmental Protection 2020, Decree No. 08/2022/ND-CP and Circular No. 02/2022/TT-BTNMT set out the responsibilities of producers and importers for packaging recycling and waste treatment in an EPR scheme.
The government will also establish the National Council for Extended Producer Responsibility, comprising domestic representatives from the public, private, and non-government sectors, to assist the Ministry of Natural Resources and the Environment (MONRE) to manage, monitor, and facilitate importers’ and producers’ EPR obligations, as well as the use of funds from the Vietnam Environmental Protection Fund (VEPF), to which operators contribute under the scheme.
The direction of travel has been positive in Vietnam for the past several years, with the establishment of the industry-led Packaging Recycling Organisation Vietnam (PRO Vietnam) in 2019 to manage recycling, campaigns and alliances by retailers, and a burgeoning environmental start-up scene. PRO Vietnam has also recently been recognized by MONRE as the body to support enterprises to recycle.
However, teething issues in implementation and operational aspects remain: both the Decree and Circular are presently undergoing revision to ensure better compliance, while accompanying documents for guidance such as a Circular guiding the use of the VEPF, and a decision on the recycling rate (Fs), are being developed.
- The next wave of EPR in Southeast Asia
Thailand
Thailand is regularly at the front of the pack in Southeast Asia when it comes to progressive environmental policies. However, the country is the sixth worst marine plastic polluter globally, meaning it has a mammoth task ahead of it to address the 3.5 million tonnes of plastic consumed annually by 2027, a goal set in the Roadmap on Plastic Waste Management 2018-2030.
An EPR policy is being developed by the Ministry of Natural Resources and Environment, officially known as the Sustainable Packaging Waste Management Act. It is still early days, with the law expected to come into force 2027. As with other schemes, the effectiveness will rely on the details of the policy; a current draft of the bill contains tight phase-in periods and fees for private operators have yet to be specified.
However, overall momentum is positive, with a new government at the helm keen to attract and keep international investment and growing local buy-in for sustainability efforts at the business and consumer level.
Malaysia
Malaysia has also set ambitious targets, with a plastic packaging recycling target of 100% and minimum recycled content requirements of 15% by 2030, outlined in the Malaysian Plastics Sustainability Roadmap 2021-2030.
Taking an alternative policy approach, Malaysia implemented a voluntary EPR scheme in 2023, which is due to become mandatory in 2026. The government is inclined towards the implementation of a single Producer Responsibility Organization (PRO) system at present and has been working closely with the Malaysian Alliance for Recycling Associations (MAREA), a voluntary, industry-led platform, to lead EPR-related activities.
While pilot schemes in Perak, Selangor, Penang, and Langkawi (a small tourist island in Kedah state) have been launched, the EPR movement has gained limited traction overall, with low consumer awareness and a continued lack of recycling and waste management infrastructure. The Malaysian government has plans to release the Circular Economy Roadmap for Solid Waste which should contain more detailed guidelines for the voluntary EPR scheme by the end of the year.
Indonesia
Indonesia has also taken a voluntary approach to EPR, with targets set in the Waste Reduction Roadmap – Ministerial Regulation 75/2019 – for reducing waste production by 30% by 2029. The roadmap requires annual baseline reports from producers, and further plans to create a roadmap to reduce waste by at least 30% for the next ten years.
As a voluntary scheme, there are no enforcement measures yet, though the Ministry of Environment and Forestry (KLHK) has successfully collected roadmaps from a significant number of its targeted 100 producers. Meanwhile, in 2020, industry set up the Indonesia Packaging Recovery Organisation (IPRO) to consolidate waste recovery strategies.
While the existence of a voluntary scheme is a positive development, and industry actions have been on-going for several years, there is a need for greater momentum. It is unlikely that there will be significant policy development in the space during an election year in Indonesia.
Singapore
Since 2022, the Singapore government has imposed tracking and monitoring requirements under the Mandatory Packaging Reporting scheme on market operators to submit packaging data and 3R (reduce, reuse, recycle) plans to the National Environment Agency (NEA), to inform the development of a more comprehensive EPR scheme. The government will also roll out a Beverage Container Return Scheme from April 1, 2025.
Issues have been identified regarding the creation of a broader recycling value chain including the lack of high-quality plastic feedstock and plastics recycling infrastructure. The government is looking to attract investment in chemical recycling and set up a pilot plastic recovery facility. It has also commissioned a feasibility study for an EPR scheme in Singapore, with the tender results expected soon.
Despite Singapore’s track record in policy leadership and implementation, the current situation for plastic recycling is surprisingly nascent, though there is gathering momentum towards a comprehensive EPR scheme.
Cambodia
In 2021, the government placed improvement of solid waste and plastic management on the national agenda, as outlined in the Municipal Solid Waste Management Policy 2020-2030. With support from international development agencies GIZ and UNDP, the Ministry of Environment is studying the design of an EPR model, including a sub-decree on plastic management and recommendations on economic measures to discourage the use of plastics and incentivize the use of alternatives.
While practical progress has been slow, there is positive momentum in Cambodia. The new administration under Prime Minister Hun Manet presents an opportunity to deliver greater details on how an EPR scheme, as well as laws on issues such as single-use plastic, would be developed and implemented. This may be a focus for him in subsequent political terms, though it is not a top priority for him in the near term.
Conclusions
The issue of marine plastic pollution is a global challenge, and one that is particularly acute in Southeast Asia, where policy development to address the problem is finally gaining some momentum.
With legislation passed in the Philippines and Vietnam and pilot schemes or draft legislation in a handful of markets, other economies in the region may yet be inspired to develop or formalise EPR schemes.
It is clear however that the details of the schemes are crucial to their effectiveness. Private operators, through their initiatives in redesign and investment in manufacturing, and/or coordination with producer responsibility organisations (PROs), are an essential part of the solution. To capture the greatest amount of waste, it is important that the rules for manufacturers are clear, schemes are transparent, and participation by all responsible organisations – including domestic operators and local governments – is encouraged.
Southeast Asia Public Policy Institute: Circular ASEAN programme
‘Circular ASEAN’ is one of the Institute’s core programmes. The programme aims to explore best practice policy for building the circular economy in Southeast Asia, support the development of the economic case for circularity in ASEAN, and convene stakeholders and policymakers to drive the conversation on circularity.
Learn more about Circular ASEAN
About the Southeast Asia Public Policy Institute
The Southeast Asia Public Policy Institute is a research institute based in Bangkok and Singapore, working across the region. Our mission is to support the development of solutions to the most pressing public policy challenges facing Southeast Asia in the 21st century. The Institute undertakes in-depth research to develop actionable policy solutions on a range of issues across sustainability, technology, public health, trade, and governance. We convene dialogues with stakeholders and decisionmakers to drive discussion on the challenges and opportunities facing markets across the region. The Institute draws on a network of in-market researchers, advisors, and partners to provide insights and recommendations for governments, policymakers, and businesses.
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