Extended producer responsibility

Russia: EPR – Revised product fee rates

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).

Russia: EPR - Amended regulation on reporting of products released on the Russian market

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.

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.

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