As of 10 November 2018, importers and manufacturers of products subject to recycling, reuse and recovery (utilisation) are required to pay the revised fee rates if they do not perform utilisation of these products (i.e. either themselves or by joining a compliance scheme or by entering into a contract with a waste disposal operator). The fees will apply to products placed on the market as of 2018 within the framework of extended producer responsibility (EPR).
Extended producer responsibility
As of 4 August 2018, manufacturers and importers of products subject to the extended producer responsibility (EPR) are required to follow the revised procedure of annual reporting of products and packaging placed on the Russian market.
The amendments to the existing procedure clarify that the goods and packaging exported from Russia are not to be included into the total quantity of reported products.
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.
Starting from 2018, importers and manufacturers of products subject to utilisation targets (within the extended producer responsibility - EPR – concept) are required to comply with the revised utilisation targets.
The highest targets (25% for 2018 and 45% for 2020) have been set for corrugated paper and paperboard and corrugated paper and cardboard packaging.
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:
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.
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.
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.