Extended producer responsibility

Russia: Amended law on the environmental expert assessment

As of 28 December 2017, organisations planning any activity that is subject to the environmental expert assessment (i.e. any activity that has a potentially high environmental impact) are required to comply with the revised provisions governing the performance of environmental expert assessment.

Russia: Revised list of products subject to utilisation targets (extended producer responsibility)

Starting from 1 January 2018 manufacturers and importers of products included into the revised list of products subject to the extended producer responsibility (EPR) obligations are obliged to comply with the utilisation targets set for such products and packaging or to pay the environmental charge.

The adopted list replaces the list adopted by Government Direction No. 1886-p dated 24 September 2015.

Russia: How to calculate and report the environmental charges for 2017 within the EPR framework

Manufacturers and importers of products subject to recycling targets (i.e. those subject to the extended producer responsibility) must pay the environmental charge for 2017 before 15 April 2018, if they are required to pay such a charge.

Operators subject to the environmental charge payment are required to submit to the authorities, before 1 April of the year following the relevant reporting year the following documents:

Russia: Administrative liability for non-fulfilment of extended producer responsibility

Importers and manufactured of certain product categories are required to organise recycling of wastes resulting from the use or consumption of such products, in accordance with the recycling targets set by the Government of the Russian Federation. The obligation of operators (importers and manufacturers) is considered to be fulfilled from either the moment of submitting a report on the fulfilment of the set recycling targets or from the moment they have paid the required environmental charge.

Russia: Which law sets the recycling targets for 2017?

The Federal Service for the Supervision of the Use of Natural Resources has clarified which legislation is to be applied by importers and manufacturers in determining their obligations within the extended producer responsibility concept (EPR).

Russia: EPR. Proposal to submit environmental charge calculation electronically

Manufacturers and importers of products subject to recycling after the loss of their consumer properties (e.g. electronic equipment, cardboard and paper packaging and textile products) within the extended producer responsibility framework, might soon be able to submit the environmental charge calculation reports in electronic form online.

Russia: Extended producer responsibility lies with trademark owners

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.

Russia: Extended producer responsibility will not apply to product components

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.

Russia: WEEE management. Legal framework.

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).

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