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Vietnam is tightening its control over scrap imports, balancing industrial demand with a firm commitment to environmental protection. For foreign-owned enterprises relying on imported scrap materials, these new regulations present both a compliance challenge and an opportunity to build more resilient supply chains.
This article, drawing from our experience in environmental legal consulting and international trade, provides a clear roadmap for FDI enterprises to understand and adapt to the critical imported conditions for scrap iron and steel.
Key Takeaways:
- New Technical Standards: The new national technical regulations, specifically QCVN 31:2024/BTNMT, will be enforced from June 30, 2025, setting stricter limits for imported scrap like iron and steel scrap.
- Direct-Use Only: Only production facilities with the appropriate recycling technology are permitted to import scrap, eliminating intermediary traders from the production process.
- Mandatory Environmental Deposits: Importers must secure an environmental protection deposit based on the volume of their shipment, a key financial requirement for importing scrap.
- Approved Materials List: Imports are restricted to a list of scraps permitted for import issued by the Prime Minister, which includes scrap iron, steel, and cast iron.
- Rigorous Customs Scrutiny: Customs procedures now require comprehensive documentation and strict compliance with environmental protection standards before any imported scraps are cleared.
The Legal Framework Governing Scrap Iron And Steel Imports
Navigating Vietnam's regulatory landscape requires a clear understanding of the key legal documents governing scrap. The foundation of these changes is the Law on Environmental Protection 2020, which sets a national mandate for the sustainable use of natural resources and environment. All organizations and individuals must stay updated because while scrap is a vital production material, it carries significant environmental risks if not managed correctly.
Core Legal Instruments
The primary regulations governing scrap imports include:
- Law on Environmental Protection 2020: The overarching law emphasizing environmental responsibility in all economic activities.
- Decree 08/2022/NĐ-CP: This decree details specific implementation rules, including the critical environmental protection deposit requirements outlined in Article 46.
- Decision 13/2023/QĐ-TTg: This decision provides the official list of scrap permitted for import from foreign countries as raw materials for production, including various forms of iron and steel.
- QCVN 31:2024/BTNMT: This is one of the key issued national technical regulations from the Ministry of Natural Resources and Environment. Effective June 30, 2025, it establishes precise technical requirements for imported iron and steel scrap.
FDI enterprises are required to demonstrate that their processing capabilities and control systems meet Vietnam's stringent standards, making familiarity with these documents extremely meaningful.
Business And Environmental Conditions For Scrap Traders
Before an FDI enterprise can even consider importing scrap, it must meet foundational business and environmental protection requirements such as: Having a production facility with technology and equipment for recycling and reusing scrap that meets environmental protection requirements according to regulations; Having a production facility with technology and equipment for recycling and reusing scrap that meets environmental protection requirements according to regulations; Meeting the conditions for warehouses or storage yards for imported scrap; Having an environmental license, environmental protection deposit... These prerequisites are designed to ensure that only qualified and responsible entities participate in the trade.
It is important to note that only importing scrap from foreign countries as raw materials for production only for that enterprise is allowed.
Business Registration Requirements
The business line for scrap trading is not categorized as a conditional sector. Enterprises simply need to register the industry code 46697 (Wholesale of metal and non-metal scrap) under the Prime Minister's Decision 27/2018/QD-TTg.
Environmental Protection Requirements
The need to meet environmental protection requirements is far more demanding. Depending on the scale of operations, a company must prepare an Environmental Impact Assessment (EIA) and secure the proper environmental permits. Furthermore, the facility's location must align with approved zoning plans. The site must be equipped with physical barriers and comprehensive systems to minimize negative impact on the environment from wastewater, emissions, and other waste.
Import Conditions For Scrap Iron And Steel In 2025
The core of the new regulations lies in the specific conditions applied to the scrap materials and the importing entities. The 2025 rules are designed to elevate the quality of imported scrap and ensure it is handled responsibly.
Eligible Materials For Import
All imported scrap must be on the official government-approved list of scrap allowed for import. Decision 13/2023/QĐ-TTg explicitly permits the import of iron, steel, and cast iron scrap, which are essential raw materials for Vietnam's steel industry.
Environmental Technical Standards
From June 30, 2025, all iron and steel scrap must comply with QCVN 31:2024/BTNMT. These technical regulations set measurable limits on heavy metals, impurities, and radiation levels.
| Key Standard Under QCVN 31:2024/BTNMT | Requirement |
| Other impurities remaining are not iron, steel, cast iron removed from imported iron, steel, cast iron scrap. | In each imported shipment of iron, steel and cast iron scrap, the total mass of these impurities must not exceed 1% of the shipment's mass. |
| Hazardous Materials | Must contain no explosives, weapons, or other dangerous goods. |
| Radioactivity | Must not exceed established national safety thresholds. |
This change directly impacts the businessoperations, requiring a review of supply chains to ensure that steel scrap imported from international sources meets these standards.
Conditions For Importers And Production Facilities
The regulations place heavy responsibility on the importer. With current regulations, only end-users (the manufacturers themselves) are permitted to import scraps.
Only Manufacturing Facilities Are Allowed To Import
The new framework eliminates intermediary traders. An enterprise must have its own production facilities with the technology and equipment for recycling. The facility’s warehouses must meet all environmental protection standards specified in its environment license.
Environmental Protection Deposit Requirement
A significant financial requirement is the mandatory environmental protection deposit. According to Decree No 08/2022/ND-CP, this deposit must be made before customs clearance. The amount is tiered based on the volume of iron and steel scrap being imported.
| Scrap Volume | Required Deposit Rate |
| < 500 tons | 10% of shipment value |
| 500 to < 1,000 tons | 15% of shipment value |
| ≥ 1,000 tons | 20% of shipment value |
This deposit serves as a financial guarantee that the importer will manage the scrap responsibly. It is paid and refunded in Vietnamese Dong and enjoys the agreed interest rate according to the provisions of law.
Commitment To Re-Export Or Treatment
Importers must sign a formal commitment to either re-export or safely treat any shipment that fails to meet Vietnam's quality and environmental standards upon inspection.
Customs Procedures And Quality Assessment
The customs process has become more rigorous, with a focus on verification by relevant state management agencies. A smooth clearance process depends on meticulous preparation.
Electronic Declaration And Inspection Steps
Importers must submit an electronic customs dossier that includes:
- Certificate of Origin (CO) and Certificate of Quality (CQ).
- Photographs or detailed descriptions of the scrap material.
- A scanned copy of the environmental deposit certificate.
- A quality inspection certificate from a designated assessment body.
- The signed commitment form for re-export or treatment in case the imported scrap does not meet environmental regulations.
- Quality certificate of the exporting country (if any); Certificate of Origin (if any).
- Legal documents of the importing organization (Business Registration Certificate, Environmental License).
Pre-Shipment Inspection And On-Site Verification
All scrap imports must undergo a quality assessment before customs clearance. We strongly advise clients to engage with an accredited inspection agency in the exporting country to certify the shipment before it leaves the port to prevent costly delays at Vietnamese ports. It should be noted that certificates issued abroad must be consular legalized to be used in Vietnam.
Compliance Strategy And Risk Management For 2025
With the QCVN 31:2024/BTNMT a robust compliance strategy will not only prevent legal trouble but also enhance an enterprise's reputation.
How To Minimize Environmental And Legal Risks
Successful FDI enterprises invest in on-site sorting equipment and automated monitoring systems. Establishing an internal legal compliance department is crucial for staying ahead of regulatory changes and managing environmental risks.
We recommend conducting trial imports under the new national technical regulations to test supply chains and internal processes, ensuring a seamless transition and avoiding disruptions to production materials flow.
Conclusion: Building Sustainable Import Operations
Mastering Vietnam's new scrap import regulations requires focusing on four pillars: legal adherence, environmental integrity, financial preparedness, and procedural accuracy. By preparing in advance, FDI enterprises can secure a stable supply of raw materials while demonstrating a commitment to sustainable development. This proactive approach builds a strong ESG profile, which is vital for long-term success in the region.
As specialists in environmental policy, we have extensive experience guiding FDI corporations in the metallurgy and recycling sectors, including for non ferrous metals like copper waste and aluminum waste, through these complex regulatory shifts.
Frequently Asked Questions
What is the most significant change in Vietnam's 2025 scrap import regulations?
The most critical change is the mandatory enforcement of QCVN 31:2024/BTNMT starting June 30, 2025. This new national technical regulation sets much stricter limits on impurities in imported iron and steel scrap, requiring suppliers and importers to meet a higher quality benchmark.
How is the environmental protection deposit calculated for a shipment of iron scrap?
The deposit is calculated as a percentage of the total shipment value and varies by volume. A shipment under 500 tons requires a 10% deposit, a shipment from 500 to under 1,000 tons requires 15%, and a shipment of 1,000 tons or more requires a 20% deposit. This must be in place before importing scrap.
Can a trading company import scrap metal into Vietnam for resale to manufacturers?
No. Under the current regulations, only organizations and individuals that own a production facility and directly use the scrap as a production material are permitted to import. This measure is designed to ensure accountability and prevent the accumulation of unprocessed scrap.
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