Environmental protection reporting obligations of manufacturing projects

Environmental protection reporting is a mandatory requirement for manufacturing projects under environmental protection laws. During project implementation, enterprises must accurately identify the subjects required to report, types of reports, reporting contents, submission deadlines, and competent receiving authorities to ensure legal compliance and mitigate legal risks. This article summarizes and analyzes the current legal regulations, assisting project owners and manufacturing facilities in fully and timely fulfilling their environmental protection reporting obligations. 

1. Subjects, types, and contents of reports⁵ 

Project owners are responsible for preparing and submitting environmental protection reports to competent state authorities in accordance with the law. 

Environmental protection reports include:  

• Annual environmental protection reports, with the reporting period calculated from January 1 to December 31 of the reporting year; 

• Ad-hoc environmental protection reports, submitted upon request of competent state authorities. 

The contents of environmental protection reports include⁶: 

• Environmental protection reporting contents applicable to project owners and manufacturing facilities subject to the requirement for an environmental permit, as prescribed in Form No. 05.A, Appendix VI issued together with Circular No. 22/2022/TT-BTNMT; 

• Environmental protection reporting contents applicable to project owners and manufacturing facilities subject to environmental registration, as prescribed in Form No. 05.B, Appendix VI issued together with Circular No. 22/2022/TT-BTNMT. Entities exempted from environmental registration in accordance with Article 32 of Decree No. 08/2022/NĐ-CP are not required to carry out environmental protection reporting.

Accordingly, the main contents of environmental protection reports include: 

• Performance results of environmental protection facilities and measures for waste treatment; 

• Results of remediation and compliance with environmental protection requirements imposed by inspection authorities and competent state agencies (if any); 

• Results of periodic environmental monitoring and supervision, as well as automatic and continuous monitoring; 

• Management of solid waste and hazardous waste; 

• Management of imported scrap materials (if any); 

• Environmental monitoring service activities (if any); 

• Other results, activities, and environmental protection measures. 

2. Reporting Timeline and Submission Methods

Reporting timeline: Project owners and manufacturing facilities must submit annual environmental protection reports (covering the period from January 1 to December 31) no later than January 15 of the following year⁷. 

Reporting methods: Environmental protection reports may be submitted in one of the following forms: 

• Paper-based reports, bearing the signature of the authorized person and the official seal of the entity. Statistical appendices attached to the report must be stamped across pages. Reports in this form may be submitted via the methods specified in points (b), (c), and (d) below; 

• Electronic reports, prepared in the format prescribed by competent state authorities or digitized from paper-based reports, bearing electronic signatures and electronic seals of the entity. Reports in this form may be submitted via the methods specified in points (a) and (đ) below. 

Reports may be submitted to the receiving authorities through one of the following methods:  

a) Submission via environmental information systems at various levels or other local informationsystems;

b) Direct submission andreceipt;

c) Submission and receipt via postalservices;

d) Submission and receipt viafax;

đ) Submission and receipt via email systems; 

e)Othermethods as prescribed by law.

3. Authorities receiving the reports⁸ 

Environmental protection reports shall be submitted to the following authorities: 

• The authority issuing the environmental permit (for projects and manufacturing facilities subject to environmental permit requirements) or the authority receiving environmental registration (for projects and manufacturing facilities subject to environmental registration requirements); 

• The Department of Agriculture and Environment of the locality where the project or facility conducts manufacturing, business, or service activities; 

• The People’s Committee at the commune level; 

• The investor in the construction and operation of technical infrastructure of concentrated production, business, or service zones or industrial clusters (for facilities located within economic zones, concentrated production, business, or service zones, or industrial clusters).

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^{(5) Article 114 of the 2020 Law on Environmental Protection} 

^{(6) Article 66 of Circular 02/2022/TT-BTNMT}

^{(7) Point a, Clause 19, Article 1 of Circular 07/2025/TT-BTNMT}

^{(8) Clause 3, Article 4 of Circular 07/2025/TT-BNNMT}

Date written: 20/01/2026

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

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Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.

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