Conduct research and propose solutions related to importing plastic scrap and packaging [Vietnam]


 

Annex 1 - 2: The Service

NAME: TBC

ASSIGNMENT: Conduct research and propose solutions related to

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importing plastic scrap and packaging

IUCN REPORTING MANAGER: Bui Thi Thu Hien, Marine & Coastal Coordinator

LOCATION: Vietnam

DURATION: 26 June - 15 Oct 2023

To apply, please submit to Nhung.PHAMHONG@iucn.org your updated CV.

I. BACKGROUND

Vietnam's per capita plastic consumption has increased 11 times, from 3.8 kg/person/year in


digits per year [2], in which, the plastic packaging industry achieves a growth rate of 25% per

year and accounts for the highest proportion of revenue in the structure of the plastic industry

(38-39%) [3]. In 2020, nearly 114,500 tons of plastic beverage bottles, 231,000 tons of PET

bottles [4], 2.2 million tons of plastic bags, 290,000 tons of plastic boxes, cases, and more than


The World Bank report [7] shows that each year, an average of 3.9 million tons of PET, LDPE,

HDPE, and PP plastic are consumed in Vietnam.

Increased consumption of plastic products and plastic packaging has resulted in a significant

rise in the flow of plastic waste that leaks into the environment. The amount of plastic waste

generated in Vietnam is recorded at about 2.9 million tons in 2021 with an enlarging rate of

about 5% per year [8]. In 2018, the amount of plastic waste released into Vietnam's oceans

was estimated by IUCN at 453,000 tons [9].

[1] IUCN-EA-QUANTIS, 2020. Hướng dẫn quốc gia về xác định điểm nóng ô nhiễm nhựa và xây dựng hành động, Báo cáo cho Việt Nam.

https://plastichotspotting.lifecycleinitiative.org/wp-content/uploads/2020/12/Vietnam_Finalreport_2020_10_22.pdf
[2] FiinResearch, 2021. Industry Preview: Vietnam Plastic Market 2021. https://business.gov.vn/nghien-cuu-thi-truong/chi-tiet-an-pham/67
[3] https://vietnamreport.net.vn/Xuc-tac-Covid19-khien-nganh-bao-bi-phan-cuc-10141-1006.html
[4] IUCN-EA-QUANTIS, 2020. Hướng dẫn quốc gia về xác định điểm nóng ô nhiễm nhựa và xây dựng hành động, Báo cáo cho Việt Nam.

https://plastichotspotting.lifecycleinitiative.org/wp-content/uploads/2020/12/Vietnam_Finalreport_2020_10_22.pdf
[5] GA Circular (2019) Full Circle: Accelerating the Circular Economy for Post-Consumer PET Bottles in Southeast Asia,

http://www.gacircular.com/full-circle/ (cited by Eunomia, 2022)
[6] IUCN-EA-QUANTIS, 2020. Hướng dẫn quốc gia về xác định điểm nóng ô nhiễm nhựa và xây dựng hành động, Báo cáo cho Việt Nam.

https://plastichotspotting.lifecycleinitiative.org/wp-content/uploads/2020/12/Vietnam_Finalreport_2020_10_22.pdf
[7] World Bank Group, 2021. Market Study for Vietnam: Plastics Circularity Opportunities and Barriers. Marine Plastics Series. World Bank,

Washington, DC. © World Bank
[8] Tuệ N.T., Dũng L.V., Quy T.Đ., Hiếu P.V., Hoài T.T., Linh L.T.K., Khoa N.D. Báo cáo hiện trạng chất thải nhựa năm 2022, WWF-Việt Nam.
[9] IUCN-EA-QUANTIS, 2020. Hướng dẫn quốc gia về xác định điểm nóng ô nhiễm nhựa và xây dựng hành động, Báo cáo cho Việt Nam.

https://plastichotspotting.lifecycleinitiative.org/wp-content/uploads/2020/12/Vietnam_Finalreport_2020_10_22.pdf

The plastic industry - the second highest growth industry in Vietnam with a revenue of 15.6

billion USD in 2018 - has to import up to 85 - 90% of plastic materials because the domestic

supply does not meet the production demand in terms of uniformity between quality and

quantity [10]. The growth rate of the industry seems to be closely related to the amount of

imported raw materials. From 2013 to 2017, Vietnam's plastic industry imported recycled

plastic at an average of 91,400 tons/year, making Vietnam fourth among 10 ASEAN countries

[11]. After China's ban on importing plastic waste/scrap from abroad took effect in early 2018,

Vietnam became the world's second-largest importer of plastic waste/scrap [12].

While the Government is struggling to manage its own domestic plastic waste, this

international influx of plastic waste certainly contributes to the proportion of unmanaged and

leaking plastic waste into the environment.

Currently, the formal sector mainly uses imported plastic waste/scrap for recycling, while

domestic waste is collected in craft villages. The craft villages also use imported plastic

waste/scrap for recycling. In EPR schemes, domestic waste flows can be altered and this can

create a need for other waste sources from informal recyclers. Shortages can then be made

up by imported sources, whether legal or not. The proliferation of sources of illegal imports

will put pressure on not only the enforcement system but also the control of profiteering in

EPR schemes [13].

Controlling plastic scrap from the international market is the most controversial and

challenging issue for the Government due to the complexity of the type and the magnitude

of the volume. Scrap is a material that is recovered, classified, and selected from materials

and products that have been discarded from the production or consumption process that can

be reused as raw materials for another production process. While the Ministry of Natural

Resources and Environment (MONRE) considers scrap as waste that can be reused, the

Ministry of Industry and Trade (MOIT) and manufacturers consider it as input material.

Therefore, MONRE requires imported plastic scrap to meet the provisions of the National

Technical Regulation on the environment for scrap [14]. The certificate of eligibility for

environmental protection in the import of scrap as raw production materials must be issued

by the Ministry of Natural Resources and Environment [15]. However, import activities are

carried out and supervised by the General Department of Vietnam Customs under the

Ministry of Finance (MOF) through Customs procedures [16].

On July 22, 2021, the Prime Minister issued Decision No. 1316/QD-TTg approving the Project

to Strengthen the Management of plastic waste in Vietnam (Project) with the aim to: (1)

strengthen the management of solid waste in Vietnam, from central to local levels,
[10] Hiệp hội nhựa Việt Nam. Tổng quan ngành nhựa Việt Nam. Xem tại http://vpas.vn/gioi-thieu/tong-quannganh.
html (truy cập ngày 1 Tháng 03 năm 2019); Vietnam Industry Research and Consultancy (2018), Vietnam

Plastics Comprehensive Report Q2/2018.
[11] Xuân Long, Trần Vũ Nghi and Lê Thanh (ngày 3 Tháng 04 năm 2019). Siết chặt nhập nguồn phế thải nhựa vô tội vạ. Xem tại
https://tuoitre.vn/siet-chat-nhap-nguon-phe-thai-nhua-vo-toi-va-20190403074535505.htm (truy cập ngày 12 Tháng 12 năm 2019)

[12] Hook, L. and Reed, J. (25 October 2018). Why the world’s recycling system stopped working. Xem tại
https://www.ft.com/content/360e2524-d71a-11e8-a854-33d6f82e62f8 (truy cập ngày 18 Tháng 05 năm 2019).

[13] Phuong N. H. (2021). Policy effectiveness assessment of selected tools for addressing marine plastic pollution. Extended Producer
Responsibility in Viet Nam. Bonn, Germany: IUCN Environmental Law Centre. 28pp
[14] Quy Chuẩn Kỹ Thuật Quốc Gia Về Môi Trường Đối Với Phế Liệu Nhựa Nhập Khẩu Làm Nguyên Liệu Sản
Xuất (QCVN 32:2018/BTNMT, ngày 14 Tháng 09 năm 2018).

[15] Ibid.; Nghị Định Sửa Đổi, Bổ Sung Một Số Điều Của Các Nghị Định Quy Định Chi Tiết, Hướng Dẫn Thi Hành
Luật Bảo Vệ Môi Trường (40/2019/ND-CP, 13 Tháng 05 2019). Điều 3 (28-34).
[16] Phuong, N.H. (2020). The legal, policy, and institutional frameworks governing marine plastics in Viet Nam. IUCN, Bonn, Germany

contributing to the implementation of the national strategy on integrated solid waste

management by 2025, with a vision to 2050; (2) contribute to building a circular economy

model in Vietnam with the orientation of reducing the use of single-use plastic products and

non-biodegradable plastic bags; (3) enhance reusing, recycling and disposing of plastic waste.

In order to achieve the above goal, the Project has set out the task of investigating, surveying,

and assessing the current situation of generation, collection, recycling, and treatment of

plastic waste, including the content of the overall assessment of the current state of plastic

waste, producing and using plastic products ensuring environmentally friendly, disposable

plastic products and non-reusable plastic bags; Surveying and assessing the production and

import of products and goods containing microplastics and the impact of microplastics on the

environment; and Investigating, surveying and evaluating the current situation of arising,

collection, recycling, and treatment of plastic waste and propose solutions to improve the

management efficiency.

Performing the function of state governance of the environment in the management of

environmental pollution in general and plastic pollution in particular, the Department of

Environmental Pollution Control (KSONMT) - MONRE is responsible for synthesizing

information, statistics on plastic waste (including arising, treatment and recycling) and plastic

production, scrap import activities within the scope and powers assigned.

This activity is carried out within the framework of “Strategic cooperation between IUCN

Vietnam and Packaging Recycling Organization Vietnam (PRO) on plastic waste management,

and coordinate with the Project "Reducing ocean plastic waste in Vietnam" (Project)

implemented by WWF-VN with the Department of Seas and Islands of Vietnam on behalf of

MONRE as the project lead agency; The Department of Environmental Protection (formerly

the Vietnam Environment Administration) is one of the implementation partners of the

Project.

The project selects an independent consultant in the Customs field (in collaboration with the

consultant in the Environment field recruited by WWF) to carry out and jointly implement

"Research and propose solutions related to the import of scrap plastic and packaging" to

support relevant state government agencies in the management of environmental pollution

in general and plastic pollution in particular.

II. OBJECTIVES AND SCOPE OF WORK

The objective of this consulting service is to review the regulations, functions, and tasks of

agencies related to state governance of Customs and import-export agencies (at the Ministry

of Finance and the Ministry of Industry and Trade) and compile statistics on data in specialized

activities related to the management of export/import of plastic materials, plastic products,

and plastic scraps in Vietnam:

  • Review and analyze regulations and coordination activities with relevant agencies in

ministries and sectors at central and local levels in import/export activities of plastic

scrap and plastic materials.

  • Statistics on the quantity of plastic materials, plastic scraps, and plastic products

imported into Vietnam and exported from Vietnam with HS codes according to

regulations.

III. SPECIFIC TASKS FOR THE CONSULTANT

The Consultant will perform the following tasks:

Task 1: Review, analyze and evaluate policies, legal documents, regulations, guidelines, and

reports applicable to the Customs industry, and import-export industry related to

export/import management activities import plastic scrap and plastic raw materials.

  • Review legal documents on functions, tasks, and powers of the General Department

of Customs, provincial/local Customs Departments in import/export activities of

plastic scrap and plastic materials;

  • Synthesise and evaluate Customs documents and reports on the import/export of

plastic scrap and plastic materials;

  • Review and synthesize Customs regulations and guidelines on the process of

management, storage, warehousing, and handling of plastic scraps and plastic

materials

  • Share information (review report – task report 1) with the environmental consultant

(recruited by WWF-Vietnam) to jointly complete the summary report of the

environmental consultant's task 1.

Deliverables of task 1: 01 report “Review legal documents, documents, regulations,

guidelines and reports applicable to the Customs sector related to waste import/export

management activities plastic scraps and plastic materials”. The report is shared with the

environmental consultant to jointly complete the Task 1 report.

Task 2: Investigate and make statistics of data managed by the Customs Authority on the

import/export of plastic scrap and plastic production materials in a time series of about 5

years (2018 - 2022).

  • Through focal points, specialized units in the Customs sector and related units,

conduct investigations, surveys, and collect data on the import of plastic scrap and

plastic materials. The data includes (but is not limited to): the type of scrap/raw

material, type, volume, quality, form, import/export management process, and

environmental protection regulations;

  • Coordinate with the environmental consultant to provide data to complete the

environmental consultant's report on "Statistical results and analysis of data on the

Certificates of eligibility to import plastic scrap, environmental permits in the market

of importing plastic scrap in the 5-year period (2018 - 2022)" and recommendations

for additional solutions to improve the effective management of data, environmental

management regulations for scrap/ related materials.

Deliverables of task 2: 01 report "Synthesise data on export/import of plastic scrap and plastic

production materials"; provide data for the environmental consultant and jointly complete

the summary report of the environmental consultant's task 2 “Statistical results and ana lysis

of data on the Certificates of eligibility to import plastic scrap, environmental permits in the

market of importing plastic scrap in the 5-year period (2018 - 2022).”

IV. COORDINATION IN OTHER ACTIVITIES

The Consultant will work closely with the Environmental Consultant (employed by WWF-

Vietnam) to jointly perform the assigned tasks, ensuring the results are complementary,

integrated, and consistent in the scope of results on investigation, assessment, and

management of import of plastic scrap and plastic production materials. The Customs

consultant will also coordinate with the Environmental consultant to participate in the

organization of a consultation workshop/meeting (at least 1 research kick-off workshop and


research results.

V. QUALIFICATIONS AND EXPERIENCES

Consultants must have the following qualifications and experience:

  • University degree or higher, priority is given to those who have experience in the field of

Customs and Trading.

  • At least 5 years of experience in the development, evaluation, or implementation of laws,

policies, regulations, and guidelines in the field of Customs and Trading in Viet Nam.

  • Having a good understanding and relationship with Central Customs authorities, import-

export agencies, and provinces and cities across the country.

  • Priority is given to consultants with experience in working with ODA projects and

international organizations relating to working with the environment.

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