Key Takeaways for Your Business:
- New compliance requirement: Small and medium factories/projects must now prepare and submit an Environmental Protection Agreement (EPA) to the Ministry of Environment.
- Who’s affected: Factories/enterprises with machinery/equipment for production and investment capital between USD 50,000 and USD 500,000 across six key sectors (as below).
- Timeline: Expect a 30 working day review period once your application is submitted to MOE
- Risk of non-compliance: Administrative fines, suspension or revocation of operating permits, and potential criminal liability for severe violations.
- Action required: Assess whether your factories/enterprises falls within scope and begin preparing your EPA and related documentation.
What This Means for Your Business
On 26 November 2025, Cambodia’s Ministry of Environment (“MOE”) introduced Prakas No. 9540, implementing the new procedures and guidelines for Environmental Protection Agreements for small and medium factories/ projects. This regulation affects both existing operations and ongoing projects of private individuals, private companies, state-public entities, and state entities, meaning businesses already in operation—not just new ventures—need to take action.
The owner of the project as mentioned in Annex of Prakas No. 3591 dated 06 May 2025 on Classification of Development Project Required Environmental Impact Assessment (“Prakas 3591”) are required to prepare an EPA and submit to MOE or Department of Environment to review and assess.
If your business involves machinery and equipment for production (within the scope of Prakas 3591), you will need to prepare an EPA along with an environmental management plan. This is not just a one-time filing; it creates ongoing compliance obligations.
Please reach out to us via the contacts below to discuss your specific situation.
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Disclaimer: The information provided here is for general guidance only and does not constitute legal advice. For advice tailored to your specific circumstances, please consult with qualified legal counsel.
