Russia Clarifies Requirements Under Extended Producer Responsibility System
On 12 April 2021, the Russian Federal Service for Supervision of Natural Resources “Rosprirodnadzor” published an information note to help manufacturers and importers navigate their way through the complex and numerous laws relating to their Extended Producer Responsibility (EPR) System. This information is outlined below.
Since 1 January 2021, the list of products subject to the EPR in Russia has been revised. The revised list was adopted by Governmental Resolution No. 3721-r of 31 December 2020 and currently includes 40 product groups and 10 groups of packaging. Products covered include textile products, electrical and electronic equipment, computers, monitors, batteries, tyres, kitchen appliances, etc.
On 11 December 2020, the Russian Government approved Resolution No. 2010 /2020 setting out the procedure and revised reporting on the meeting of recycling standards from 1 January 2021 until 1 January 2022. The reports must be submitted to Rosprirodnadzor in electronic form before 1 April in the year following the reporting year. The report must contain information about products released on the Russian market during the reporting year, and the fulfilment by the importer or manufacturer of the set of recycling standards.
The procedure, forms and declaration for manufacturers or importers to declare the number of goods and packaging placed on the market in the previous calendar year is set out in the Resolution No. 1417, 2015 (as amended by Resolution No. 868, 2018).
The procedure for calculating the amount of the environmental fee and payment of the fee is approved by Resolution No. 1073, 2015. Manufacturers and importers are obliged to independently manage their product and packaging waste, or alternatively pay an environmental fee.
The calculation of the environmental fee for the reporting year 2020 is based on the number of goods and packaging placed on the market for household use in 2019, applying the recycling standards and rates for environmental tax for each product group or packaging group by manufacturers and importers that do not independently manage the waste from their covered products and packaging in accordance with Resolution No. 284/2016.
The form for calculating the amount of the environmental fee was approved by Rosprirodnadzor Order No. 488/2016.
In accordance with paragraphs 1.1, 1.2 of Article 24.2 of the Law No. 89-FZ “On Production and Consumption Waste”, manufacturers and importers are obliged to ensure compliance with the recycling standards from the moment of their initial sale of the product in the territory of Russia.
The declaration and reporting are provided:
- By importers – to Rosprirodnadzor
- By producers of goods – to the territorial body of Rosprirodnadzor at the place of state registration of the manufacturer of goods
The environmental fee is paid by transferring funds in the Russian currency as follows:
- By manufacturers – to the account of the territorial body of the Rosprirodnadzor in the Federal Treasury at the place of state registration of the payer
- by importers – to the account of Rosprirodnadzor in the Federal Treasury
If the payer is both a manufacturer of goods and an importer of goods, the environmental fee is paid by transferring funds in the currency of the Russian Federation to the account of the Rosprirodnadzor in the Federal Treasury.
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