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.
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).
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.
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.
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).
The Ministry of Natural Resources and Ecology has submitted a proposal that would impose liability on associations of manufacturers and importers to report on the fulfilment of recycling targets within concept of extended producer responsibility (EPR). Currently, only importers and manufacturers of products subject to EPR are required to submit such reports.
According to the recent clarification published by the Ministry of Natural Resources and Ecology, it is the manufacturer (importer) that sells to the end user products the use or consumption of which result in waste generation that is responsible to achieve the recycling targets.
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