A letter issued by the Russian environmental protection authority (RosPrirodNadzor) No. AC-10-02-36/13739 dated 28 June 2017, explains that it is the trademark owner who is responsible for compliance with the recycling targets or for paying the environmental charge in relation to products and packaging they have placed on the Russian market.
Waste management/ waste generation
The Ministry of Natural Resources and Ecology has drafted amendments to the Law on Industrial and Consumer Wates No. 89-FZ. The amendments would clarify that manufacturers and importers of product components (rather than finished products) or any materials that are to be used for manufacturing other goods will not have to comply with any recycling targets within the extended producer responsibility (EPR) concept.
Management of waste electrical and electronic equipment (WEEE management) is gaining more and more importance all over the world. Although Russia tends to lag behind the EU in implementing environmental and waste management regulations, it has recently introduced the concept of extended producer responsibility (EPR) that imposed WEEE management obligations on manufacturers and importers of electrical and electronic equipment (EEE).
Draft amendment to Federal Law on Industrial and Consumer Wastes and to some other regulatory instruments aims to exempt organisations that dispose of (neutralize, landfill or recycle) wastes at their own waste disposal facilities from having to contract an external waste disposal operator. In order to be able to qualify for this exemption, the organization would have to submit documentary evidence that it has the possibility to neutralize, landfill and/or recycle solid municipal wastes at its own facilities.
The Ministry of Natural Resources and Ecology has submitted a proposal that would impose liability on associations of manufacturers and importers to report on the fulfilment of recycling targets within concept of extended producer responsibility (EPR). Currently, only importers and manufacturers of products subject to EPR are required to submit such reports.
All organisations that perform “waste management activities” in Russia involving industrial and consumer wastes, are required to use a revised statistical reporting form for the period starting from 1 January 2017.
“Waste management activities” include collection, accumulation, transportation, processing, utilisation, neutralisation and disposal of wastes.