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.

In addition, the amendments will clarify that the obligation to comply with the set recycling targets will not apply to products and packaging exported from the Russian Federation.  

Further, the amendments clarify that manufacturers releasing on the market any finished products in packaging or those releasing only components used for manufacturing other products, must only comply with the recycling targets set for their packaging or pay the environmental charge. 

The Ministry of Natural Resources and the Environment (MinPrirody) is finalising the draft amendments to the Federal Law on Industrial and Consumer Wastes as well as to a number of subordinate legislation regulating the extended producer responsibility (EPR).