Vietnam has tightened recycling requirements for lubricant marketers and importers under a new extended producer responsibility regime that took effect last month, while industry groups are pushing for common standards to make it easier to trade re-refined base oils across Asia.
Decree No. 110/2026/ND-CP, issued April 1 and effective May 25, brings Vietnam’s lubricant recycling rules under a single system. Manufacturers and importers of products including engine oils must either arrange recycling themselves, hire approved recyclers or pay into the Vietnam Environmental Protection Fund. Companies generating no more than VND 30 billion (USD 1.14 million) a year from affected products may be exempt.
Under the decree, companies must submit recycling plans or declare financial contributions by April 1 each year for products sold in the previous year, with payments due by April 20. Recycling targets will be reviewed every three years, with any increase capped at 10%. The first review is expected in 2029.
The new rules come as the Asian Lubricants Industry Association calls for greater alignment of re-refined base oil standards across the region. In a white paper published in March, the Singapore-based group said re-refined base oils can match the chemical and physical properties of virgin base oils when processed correctly. Rather than identical regulations, the association is seeking common definitions and recognized quality standards that would allow re-refined oils to be traded more easily between countries.
Speaking during an ALIA webinar on May 15, Senior Technical Advisor Eric Holthusen said differing national specifications could make cross-border trade difficult and create uncertainty over product quality. The paper distinguishes re-refined base oil, which undergoes advanced processing such as vacuum distillation and hydrotreating, from recycled oil that receives only basic treatment and is generally used in lower-specification applications.
Re-refined base oils can meet API Group I, Group II or Group III specifications, depending on the process used, although ALIA notes that not all products are interchangeable. These base oils can be blended into new automotive and industrial lubricants, allowing used oils to be returned to the supply chain after processing.
ALIA said Vietnam’s lubricant oil recovery targets are expected to rise from about 15% toward 20%, with approved re-refiners playing a role in the country’s collection and recycling system. Charlotte Kehoe, ALIA council chair and technology and sustainability director at Castrol ASPAC, said some governments are defining which recyclers qualify under EPR programs, citing Vietnam as an example.
