Within the framework of the Plastic Talk dialogue on Design for Recycling (DfR) held on 11 November 2025, UNDP and IFC introduced the Draft DfR Guidelines specifically developed for PET and HDPE bottles in Viet Nam. This is a pioneering set of technical criteria, developed based on international benchmarks such as those of the Association of Plastic Recyclers (APR) and RecyClass, and adapted to Viet Nam’s existing recycling infrastructure.
The Guidelines are expected to provide a critical foundation for EPR implementation, sustainable packaging design, and the development of the domestic recycled materials market.
Why does Viet Nam need its own DfR Guidelines?
According to Mr. Peter Engel (IFC), market research shows that many PET and HDPE bottles in Viet Nam already comply reasonably well with certain design parameters, such as the use of polyolefin caps and limited direct printing. However, the widespread use of full-body shrink sleeves significantly reduces variability using Near-Infrared (NIR) spectroscopy, while high ink coverage increases the risk of contamination in recycling streams.
These design characteristics make the direct application of international standards impractical. As a result, Viet Nam requires a locally adapted DfR guideline that is globally aligned, yet compatible with domestic sorting, washing, and recycling processes.
Framework and Core principles
The draft Guideline introduces a two-stage assessment process. First, an initial screening determines whether packaging meets minimum recyclability criteria, such as containing at least 70% recyclable plastic by weight, using colors detectable by near-infrared (NIR) sorting systems, and avoiding hazardous chemicals and non-removable aluminum layers. Packaging that fails this stage is classified as non-recyclable or requiring further testing.
Packaging that passes the initial screening is then assessed in greater depth across 14 design parameters, including bottle body material, color, barrier layers (typically gas barriers), additives, caps, seals and liners, labels, shrink sleeves, printing inks, adhesives, other components, and residual product content. This comprehensive approach ensures that all components of the bottle, not only the primary body, actively support recyclability.
The Guidelines apply a four-tier recyclability rating system: 1 – Fully recyclable; 2 – Limited recyclability; 3 – Non-recyclable; and 4 – Requiring further testing. This system provides a clear and transparent basis for assessing compliance with design-for-recycling requirements, informing procurement decisions, and supporting brand commitments to circularity.
The core principles of design for recycling include using recyclable materials, minimizing material diversity within a single product, increasing the use of recycled content, avoiding incompatible components and material combinations that contaminate recycling streams, designing for easy disassembly, and preserving material quality across multiple use cycles. Among these, the key technical principle is the sink–float separation behavior of materials, complemented by maintaining natural or colorless materials to maximize output value, using detachable labels, and avoiding additives that reduce material density or contaminate recycled material streams.
- For PET bottles, recyclability is largely determined by sink–float separation during the washing process. Lightweight materials (<1 g/cm³) float and can be easily removed in the wash tank, whereas heavier materials (>1 g/cm³) sink together with contaminated PET fractions.
- For HDPE bottles, lightweight materials (<1 g/cm³) float together with contaminated PE fractions, while heavier materials (>1 g/cm³) sink and can therefore be effectively separated in the wash tank.
These principles help ensure that recycled PET and HDPE achieve higher material quality, enabling progress toward closed-loop (bottle-to-bottle) recycling.
“Recyclability begins with design”
During the panel discussion, Mr. Lâm Hoàng Hảo (Duy Tan Recycling – DTR) emphasized: “Every component of a plastic bottle—the body, cap, label, adhesive and ink—affects its recyclability. Packaging therefore must be designed correctly from the outset.” He further shared that when DTR encountered difficulties washing labels off products from a particular brand, the company worked directly with the brand owner to modify the packaging design. This experience demonstrates that supply-chain linkages and collaboration are critical to effective recycling.
Kejin Zhang from Avery Dennison noted: “The biggest challenge in emerging markets is not technology, but value. Companies need to see clear benefits when investing in DfR-compliant packaging.” She also pointed out that Viet Nam’s DfR Guidelines should be better harmonised with APR and RecyClass, particularly with regard to the ‘no-label’ criterion at the highest recyclability level, which may not be compatible with consumer information and food safety requirements in the fast-moving consumer goods sector.
The role of policy: DfR must be linked to EPR
Many experts agree that DfR can only deliver real impact when it is directly linked to EPR fee modulation mechanisms (eco-modulation). As Kejin Zhang noted: “If companies are required to pay the same EPR fee regardless of packaging design, there is no incentive to change.” Accordingly, during the dialogue, expert groups proposed that EPR fees for producers should be proportionate to the recyclability performance of packaging. Such fee differentiation would constitute the clearest and most effective financial incentive for companies across the entire value chain to adopt DfR principles.
The draft technical DfR Guidelines, together with the official circular issued by the Ministry of Industry and Trade, invite government agencies, businesses, and technical experts to provide comments on the Draft DfR Guidelines. Stakeholders are kindly requested to submit their feedback no later than 16 January 2025. For further information, please contact: Ms Hoàng Thị Diệu Linh, Programme Officer, UNDP Viet Nam – email: hoang.thi.dieu.linh@undp.org
