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Vietnam Consults on Revising its POP Regulations

The amendment supplements the conditions of exemption registration for the use of SCCP and PFOA.

As notified on its official website, Vietnam's Ministry of Natural Resources and Environment (MONRE) is consulting on the revision on Decree No. 08/2022/ND-CP Detailing a Number of Articles of the Law on Environmental Protection. The Decree stipulates provisions on the persistent organic pollutants (POPs) and raw materials, fuels, materials, products, goods and equipment containing POPs. Comments are welcome until November 4, 2023. 

The draft has brought up many changes, including adjustment on the exemption criteria for recycling responsibility under EPR scheme. (Check out the updated EPR requirements here). In particular, responsibilities of MONRE for POPs management are amended to include: "MONRE shall notify any changes as required by the Stockholm Convention on Persistent Organic Pollutants for implementation. "

The condition for exemption registration, as specified in Appendix XVII of the Decree, is also revised. The draft supplements the situations applicable to exemption registration where short-chain chlorinated paraffins (SCCP) and perfluorooctanoic acid (PFOA) are used as follows (the added content is highlighted): 

POPs name
Annex to the Stockholm Convention
Field of useCondition for exemption registration under Stockholm Convention
SCCPAIndustry 

Used in the following fields:

- Additives in the production of transmission belts/conveyor belts in the field of natural and synthetic rubber industry;

- Parts/details of rubber conveyor belts in mining and forestry industries; Adhesive (glue, etc.);

- Oil-containing preparations in leather production;

- Lubricant additives, especially for automobile engines, generators and wind power plants/facilities; in oil drilling and gas exploration, refinery for diesel production;

- Production of tubes for outdoor decorative light bulbs;

- Fireproof and waterproof paint;

- Metal processing processes (additives in lubricating oils or coolants in metal cutting or metal shaping);

- Secondary plasticizer in polyvinyl chloride, except in toys and children's products.

PFOAAIndustry

Used in the following fields:

- Photographic coating applied in film development;

- Image overlay applied to film;

- Textiles (as oil and water repellent);

- Medical devices for implantation and invasive purposes;

- Firefighting foam (class B fires);

- Production of polytetrafluoroethylene (PTFE) and polyvinylidene fluoride

(PVDF): Used in high-performance, anti-corrosion air filters, water filters and antibacterial air filters for the medical field; handing device industrial exhaust gas exchange; industrial sealants capable of preventing leakage of volatile organic compounds and PM2.5 dust;

- Production of polyfluoroethylene propylene (FEP) used in the field of high voltage wires and cables for power transmission;

- Production of fluoroelastomers to produce O-rings, belts and plastic accessories for car interiors;

- Pharmaceutical production.

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