The Ministry of Natural Resource and the Environment has published a Guidance explaining how extended producer responsibility (EPR) provisions are to be applied.
The Guidance explains that manufacturers and importers are responsible to fulfil the applicable utilization norms for products and packaging they manufacture or import into Russia. If a product or a type of packaging are included into the List adopted by Direction No. 1886-r of 24 September 2015, the manufacturers and importers of such products or packaging are required to fulfil the set utilization norms.
If a type of packaging is sold as a finished product by its manufacturer or importer directly to the end user (rather than to producers of goods that are to be placed in this packaging) – the EPR lies with this manufacturer or importer.
Manufacturers and importers placing packaged products on the market have the responsibility (EPR) for the packaging of such products (if the packaging is included into the List), even if the product itself is not subject to the EPR (i.e. is not included into the List).
If manufacturers or importers place on the market goods in a multi-use packaging, including wooden packaging, then it is the packaging manufacturers who are responsible to pay the environmental charge for this packaging, since they sell it as finished products.
Manufacturers and importers of goods must draw up a yearly declaration specifying the quantity of products and packaging released on the Russian market during the previous year, based on the information contained in the relevant customs documentation or their internal records.
If any product packaging is produced from secondary raw materials, the utilization norms for this type of packaging may be decreased by applying a reduction coefficient to these norms. In order to prove this fact, the importer of the manufacturer may use letters issued by the packaging manufacturer and/or an extract from technical / production documentation specifying the mass fraction of the secondary raw materials.