September 21, 2021
Vietnam Environment Administration
No.10 Ton That Thuyet Street, Nam Tu Liem District
Ha Noi, Viet Nam

Dear Sirs
The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit
organization with the character of a public-interest corporation. It was established inDecember 1952 in accordance with the Japanese Export and Import Trade Law under theauthorization of the Minister of Economy, Trade and Industry of Japan. The objective ofJMC is to engage in activities that enhance the common benefit of member companiesand promote the sound development of international trade and investment by themachinery industry. JMC comprises member companies engaged in machinery andsystems-related exports and foreign investments such as machinery manufacturers,
trading houses and engineering companies. At present, the total number of JMC member
companies is about 240.
Our committee handles environmental and product safety issues over products for tradeand is strongly concerned with overseas environment and product safety-related
regulations on products. From this standpoint, we would like to send the attachedcomment on Draft Decree implementing a number of articles of the Law on
Environmental Protection.
If you have any questions, please feel free to contact our secretariat (Mr. Chiaki
Morikawa, E-mail: morikawa@jmcti.or.jp).
Sincerely yours,

KANNO YasuhikoChairman
Environment Law CommitteeOur comment on Draft Decree implementing a number of articles of theLaw on Environmental Protection
September 21, 2021

Dear Sirs,
We, the Japan Machinery Center for Trade and Investment (JMC), would like to express
our gratitude to Vietnam Environment Administration for inviting comments via
WTO/TBT on the Draft Decree implementing a number of articles of the Law on
Environmental Protection.
We are firmly committed to protecting human health, product safety and the environment,
as well as complying with various regulations as defined by countries worldwide.
In this spirit, we have carefully and conscientiously examined the proposed document
regarding Draft Decree implementing a number of articles of the Law on Environmental
Protection and would like to offer the following comments toward making the proposeddecree more practicable, feasible and permanent, while ensuring appropriate andsufficient protection of the environment. We would greatly appreciate it if you could takethem into consideration carefully.

As for Article 97. Provision of information on products and packages
1. In order to promote the recycling system, shared efforts among retailers, government
and local municipalities to educate citizens or related stakeholders are a more
effective approach to ensure product waste is properly handled, collected and recycled.
We do not believe that the recycling symbol could contribute to promote recycling on
EEE (Electrical and Electronic Equipment), Machinery, Batteries (hereinafter“products”) recycling. The Recycling symbol is not effective in raising consumerawareness that product waste has to be segregated and that it is prohibited to throw
away the products. Therefore, it makes little sense to display the recycling symbol.
2. It is not clear how to deal with the specific requirements for materials, the guidanceon classification, collection, reuse, recycling and post-consumption treatment;
warning about risks in the recycling, reusing, and handling process of products, as2

these statements are not detailed in article 97.
It is also impractical for manufacturers to provide unified information, as these risks
will vary depending on available facilities and the capacity of the recyclers.
3. It is difficult for manufacturers to display a Vietnam-specific recycling symbol because
products are designed to be common to multiple countries and not necessarily
manufactured exclusively for Vietnam, and it is not feasible for importers in Vietnam
to indicate them for various types of products with a recycling symbol.
At present, the same products, such as electrical and electronic equipment, aredistributed internationally. To ensure smooth distribution, we would like to ask you to
avoid the requirement for one country’s own recycling symbol.
If, in the future, the use of symbol is unavoidably required, we would ask you toconsider using an internationally recognized symbol. We would also like to see thesymbol allowed to be displayed on websites and not just on products.
As for Article 88. Recycling rate and specifications
1. Point 7 states that Products and packages must be recycled according to thespecifications prescribed in Column 6 of Appendix 55.
As for the specifications prescribed in Column 6 of Appendix 55, we would like to see
the requirements for recycling treated as target, not mandatory requirements.
Requirements for recycling processes, such as recycling targets and procedures for
dismantling, recycling and recovery, depend on the capacity of contracted recyclers
and how governments, municipalities and citizens can support them.
2. Numerical targets for recycling rates have been set, while the rationale is unclear. It
is necessary to set a sustainable and realistic target value through demonstration
experiments of recycling treatment.
End3