Russia: Products subject to EPR might be joined into groups for utilization purposes

Draft law proposed by the Ministry of Natural Resources and Ecology aims to provide the manufacturers and importers that are subject to extended producer responsibility requirement to fulfill their utilization obligation by utilizing any products belonging to the same group of products they have produced or imported. According to the draft law, products with the same (similar) purpose and/or requiring the same (similar) way of utilization after use, are to be grouped into 43 groups.

If a manufacturer or importer has an obligation to utilize produced or imported products, they would be able to fulfill this obligation by utilizing products belonging to the same group of products they have produced or imported, rather than having to utilize exactly the same products (including packaging).

This possibility was initially provided by Federal Law No. 89-FZ on Industrial and Consumption Wastes. The list of products subject to the extended producer responsibility was adopted by Direction No. 1886-r of 24 September 2015 and includes consumer electronics, glass packaging, paper and cardboard packaging, textiles, etc.