Submission Guidelines
By The State Audit Office of Vietnam

Nowadays, sustainable development associated with environmental protection is no longer a concern of a single country but an urgent global issue and the vital factor for mankind’s existence. In Viet Nam, environmental protection is an integral factor in socio-economic development. Over the years, Viet Nam has made a lot of efforts in developing and protecting the environment. However, due to various reasons such as immediate economic goals, less awareness of environmental protection, lacking focus on communication activities and socialization in line with environmental protection, there are limitations to environmental protection, violations of the law on environment, environmental incidents, hot spots of environmental pollution, and lawsuits in the environmental field, which seriously affected production, people's lives and caused social unrest. Environmental pollution, particularly that of garbage and wastewater, including plastic waste, seriously destroying the environment and human health, has become a heated issue and draws concern of the whole society.

Clearly recognizing the environmental threat of plastic waste

The use of plastic products has become a daily habit due to its superiority, versatility, and cheapness to meet all social utility needs, at the same time its consequences also present everywhere on our planet. It is common to see plastic waste in both urban and rural areas, from plains to high mountains, from indoors to streets, fields, rivers, seas, deserts, underground, or in the air. Plastic waste being affected by nature, humans, animals and so on eventually turns into micro-plastics. Currently, micro-plastics are found to be infiltrated everywhere in the living environment, making food and drinking water unsafe, polluting the atmosphere, destroying the environment and sustainable development.

Vietnam is one of the countries with the largest plastic emissions in the world. According to statistics from the Viet Nam’s Ministry of Natural Resources and Environment, about 1.8 million tons of plastic waste is discharged into the environment each year in Viet Nam, of which 0.28 million to 0.73 million tons is discharged into the sea. Yet only 27% of it is either recycled or reused by facilities and businesses. Ho Chi Minh City (HCMC) is one of the busiest cities in Viet Nam. This rapidly urbanizing, highly populated city is facing the burning problem of garbage and plastic waste. In the project “Building a system to observe plastic waste in society and the environment” implemented by the French Embassy in Viet Nam, it has been shown that, out of 250.000 tons of plastic waste generated per year in HCMC, there are 48,000 tons taken to landfill, and more than 200,000 tons are recycled or discharged directly into the environment. The Saigon River is assessed as having the 5th largest amount of plastic waste in Viet Nam and 45th in the world. According to the statistics of waste volume in HCMC in 2020 of the Department of Natural Resources and Environment of HCMC, each day the city generates about 9,000 to 9,500 tons of domestic solid waste, of which over 1,800 tons is plastic waste (accounting for more than 20%) while only 200 tons are recovered for recycling (accounting for about 11% of plastic waste). The amount of plastic waste tends to increase rapidly from 5.5% (in 2009) to 13.9% (in 2017), which is completely consistent with the situation that plastic utensils such as plastic cups, plastic boxes, plastic bags and so on are used widely everywhere due to their convenience. In Vietnam, owing to its convenience, low price and diverse designs, plastic bags are now widely used and are distributed free of charge when selling at most markets, supermarkets, and commercial centers, bookstores, retail stores, etc. Plastic bags are thin and cheap, so the recycling units are not interested in collecting and recycling them. Besides, when discarded indiscriminately, plastic bags are easy to disperse but difficult to decompose in the environment, causing various negative environmental and socio-economic impacts, creating a burden on the state budget.

Solution of the Viet Nam’s Government

Vietnam has been implementing many strategies to reduce plastic waste and protect the environment. In 2020, Viet Nam’s National Assembly approved the Law on Environmental Protection 2020, which stipulated the functions of the SAV to perform audits in the field of environment in accordance with the provisions of Law on the State Audit Office and other relevant legal regulations, and simultaneously added regulations on the reduction, reuse, recycling and treatment of plastic waste; limited the use of single-use plastic products and non-biodegradable plastic bags; encouraged the production of environmentally friendly products to replace traditional plastic products. The Prime Minister also approved the National Strategy to 2023 on General Management of Solid Waste, with a vision to 2050 in Decision No. 2149/QD-TTg dated December 17, 2009 and Decision No. 491/QD-TTg dated 17/5/2018. Accordingly, the Strategy clearly states the goal as follows: (1) By 2015, to reduce 40% of the volume of plastic bags used in supermarkets and trade centers compared to 2010, this rate will become 65% by 2020 and by 2025, to use 100% environmentally friendly plastic bags in commercial centers and supermarkets for living purposes to replace difficult-to-decompose plastic bags. To implement the abovementioned Strategy, the Government promulgated the Project “Strengthening the control of environmental pollution caused by the use of non-biodegradable plastic bags in daily life until 2020” according to Decision 582/QD-TTg dated 11/4/2013 of the Prime Minister (the Project) which includes 2 goals: (1) By 2020, to reduce 65% of the volume of non-biodegradable plastic bags used in supermarkets, trade centers, and to reduce 50% in markets for people's living, compared to 2010; (2) By 2020, to collect and reuse 50% of the total amount of non-biodegradable plastic bag waste generated in daily living activities.

The role and efforts of the State Audit Office of Vietnam

The State Audit Office of Viet Nam (SAV), with its position and role as an organ established by the National Assembly, operating independently and only complying with the law, audits the management and use of public finances and assets with the objective of making an important contribution to the stable, sustainable and transparent development of the national financial system. Recognizing the importance of environmental protection and sustainable development, the SAV’s leaders show great interest in and consider environmental audit as one of the SAV’s prioritized activities. This is reflected in a number of the specific SAV’s actions such as: Establishing a working group on environmental audit since 2008; recognizing environmental audit in the Action Plan to implement the SAV’s Development Strategy to 2020; the SAV’s development strategy to 2030 (in the period of 2021-2030); implementing environmental audits, etc. In particular, after the 14th ASOSAI Assembly with the theme of “Environmental audit for sustainable development” was successfully held in September 2018 in Viet Nam, the promotion of environmental audit is one of the SAV’s important tasks and goals.

Thoroughly grasping the public information and burning issues on plastic waste, particularly in HCMC, from 2018, the SAV's leaders directed to conduct the audit of the implementation of the solutions to reduce the use of non-degradable plastic bags in HCMC. The audit’s objective is to evaluate HCMC’s solutions to implement the National Strategy and the Government's Project to reduce the use of non-biodegradable plastic bags, minimize the impact of plastic waste, and contribute to environmental protection.

The results of the performance audit on “The implementation of solutions to reduce the use of non-degradable plastic bags of Ho Chi Minh City according to the Government's Project” have shown that since the implementation of the Project in Ho Chi Minh City, there has been a positive change in public awareness on issues related to plastic bags.

Although this audit only covers the local level, as HCMC is the largest city in the country, the audit results also brought to the scene many limitations on the national level such as: (i) The Project and legal documents related to plastic bags fail to provide a clear definition and classification of non-biodegradable plastic bags that need to get limited in their use, leading to unclear restrictions on their use of including PE or not for pre-packaged goods; as well as plastic bags made from other materials such as PP, PA, PVC, imported nylon, reusable plastic bags, industrial plastic bags, T-bags or other multi-layer bags, thereby causing difficulties in the direction of implementation; (ii) The control of the use of plastic bags at retail units, particularly in traditional markets, still remained at low levels; tax authorities did not fully inspect, control and manage tax declarations, and the business household tax assignment is inappropriate, inaccurate, and does not fully cover business activities; (iii) There have been various errors and inadequacies in the organization carrying out the licensing and renewal procedures for the certification of biodegradable plastic bags and the enterprises producing biodegradable bags do not meet technical standards and environmentally friendly criteria, etc.

The audit’s results have also pointed out many inadequacies in the manaThe audit’s results have also pointed out many inadequacies in the management coordination between the central and local authorities, between line ministries (Ministry of Natural Resources and Environment) and local-level state management agencies in Viet Nam in implementing the Project’s objectives; and various loopholes in the management policy of non-biodegradable plastic bags. Therefore, even the act of reducing the use or banning plastic bags are insufficient to ensure the reduction of environmental pollution due to different interpretations between localities across the country, while the problem of environmental pollution is without administrative boundaries.

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Plastic waste on the side of Sai Gon river (Ho Chi Minh city) (Source: www.vietnamplus.vn)

From the current situation and inadequacies in the mechanism and administration, in addition to the recommendations for financial handling, the SAV has provided recommendations to the Ministry of Natural Resources and Environment and the City People's Committee. HCMC has adjusted the management, administration, inspection and handling of violating units. Additionally, the SAV has also made recommendations to the Ministry of Finance, the Ministry of Natural Resources and Environment to advise and submit the advice to the Government to amend and supplement mechanisms and policies on management and tax policies in order to strengthen the solutions of limiting the manufacturing of products that are difficult to decompose, and simultaneously to encourage people to use environmentally friendly plastic bags to reduce the impact of plastic waste.

In Viet Nam, the legal system on environmental protection is still somewhat inadequate and unfeasible, causing many difficulties to organizations and individuals in the process of law compliance and enforcement. The awareness of environmental protection, awareness and understanding of the role of environmental audit of organizations, businesses and people are still limited. Therefore, the SAV are faced with many difficulties carrying out environmental audits.

However, since the SAV always pay much attention on multitudes of areas - such as training to improve the quality of human resources, survey work, building audit plans, building audit objectives, criteria, and detailed audit program suitable to the reality and human resources of the audit team; identifying key objectives for in-depth audit; assigning and arranging audit time in a scientific and reasonable manner for each auditor; applying flexibly the audit methods; respecting and promoting the team’s collective intelligence; highly appreciating the responsibility and having a close relationship with the head of the audited units in providing timely information and documents for audit activities; learning from SAIs in the community of Supreme Audit Institutions and so on, the SAV's environmental audits have achieved numerous important results, with multiple solutions having been proposed for protecting the environment in general and minimizing the impact of plastic waste in particular, contributing to amending the mechanisms and policies of environmental management, raising awareness and understanding of organizations and individuals in the observance of environmental protection regulations.

In the context of the ongoing globalization, the SAV has been gradually developing, perfecting and consolidating the organization and been constantly exchanging and learning experiences from SAIs in the community of supreme auditing institutions in the region and around the world to further improve its capacity in conducting environmental audits, boosting environmental audit to a new level.

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