Clarification issued by the RosPrirodnadzor (the Russian environmental authority) explains that manufacturers and importers of certain products are required to ensure utilization of the set quantities of wastes generated as a result of such products losing their consumer properties. This requirement also applies to the packaging of such products. This concept is called “extended producer responsibility” (EPR) and was initially introduced by the Federal Law of the Russian Federation on the Industrial and Consumer Wastes.
Manufacturers and importers that do not perform the utilization themselves are required to pay the environmental charge.
If manufacturers and importers supply the relevant products in packaging, they must submit a yearly declaration specifying the quantity of products in packaging released on the market during the preceding calendar year. Manufacturers and importers must also submit reports on the fulfillment of their set utilization targets. Such targets were approved by the Government Direction NO. 2491-r of 4 December 2015.
If any finished products or packaging are imported into Russia for an organisation’s own needs and without any intention for their further distribution, then the importers of such products are not required to pay any environmental charges. Furthermore, such importers are not required to submit any declaration or reports on the supply or utilization of these products and packaging. It is important to note that the reporting obligation as well as the obligation to pay environmental charges within the framework of extended producer responsibility are only applicable to products and packaging that were manufactured or imported with the intention of their distribution to end users.
Law: Letter from RosPrirodNadzor dated 20 February 2017 No. OD-06-02-32/3380 on Environmental Charge Payment