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Increased responsibility for Russian manufacturers and importers New waste recycling rules — Do they affect your business and how should you respond?
Increased responsibility for Russian manufacturers and importersNew waste recycling rules — Do they affect your business and how should you respond?
Starting from 1 January 2015, Russia’s producers and importers of certain products have been required to recycle* waste resulting from produced and imported products and packaging. The Russian Government has adopted a list of products and packaging subject to recycling (Table 1).
In practice, it means that producers and importers of certain products and packaging must:
• Recycle a certain quantity of goods and packaging (in compliance with the respective recycling targets) themselves or by contracting an external provider; or
• Pay an annual ecological fee (hereinafter – ecofee).
New obligations
Recent legislative amendments in Russia have introduced a new term, “recycling”, that means recycling and reusing waste for new products and services. The new rules impose on producers and importers the obligation to ensure full-cycle waste management, from collection to preparation, sorting, transportation and recycling.
Table 1. Summary1 of products and packaging subject to recycling and the relevant recycling targets
Product group 2015 2016 2017
Cans of a capacity of up to 50 liters, of iron and steel 0 20 30
Tires, hard rubber articles 0 15 20
Corrugated paper/cardboard, paper containers 0 10 20
Oil products obtained from bituminous minerals, other than crude, consisting of 70% or more of oil by weight, motor oils/lubricants
Plastic bottles, of a capacity of 2 liters and more
Electric chargers, rechargeable batteries
Safety sheet glass, hollow glass (bottles, pots, storage and packaging containers, lids)
0 10 15
Paper bags/ plates/ paper stationery/ packaging
Plastic bags/bottles of a capacity not exceeding 2 liters/ packaging
Newspapers/magazines/other periodicals0 5 10
Iron and steel containers of a capacity not exceeding 300 milliliters, not fitted with equipment, aluminum containers of a capacity not exceeding 300 milliliters
Wooden windows/doors/containers
Plastic clothing/kitchenware/film/household articles
Plastic construction materials: coverings and coatings/plumbing and bathroom equipment/ containers of a capacity exceeding 300 liters/linoleum
Computers and related hardware, communication equipment, electrical household goods, cameras and video cameras, electrical household appliances and ovens of iron and steel, industrial refrigeration equipment
Machinery and other equipment (fluid cleaning units/air filters)
Articles of glass (mosaic, blocks)
0 0 5
Textiles (carpets, clothes, underwear, protective clothing)
Plastic doors/windows
Bulbs0 0 0
1 See the full list in the Government Decree No. 1886-r of 24 September 2015.
In addition to the waste recycling obligations, the new rules require producers and importers to prepare and to file the new types of reports to the competent authority (Rosprirodnadzor), which are:
• An annual declaration on the total volume of goods and packaging released into circulation (the “Declaration”) – filing by 1 April of the year following the reporting year; and
• An annual report on compliance with the recycling targets (the “Report”) – filing by 1 April of the year following the reporting year; and, if applicable
• An Ecofee Calculation Form with respect to goods and packaging subject to recycling (the “Calculation Form”) – filing and paying the respective amount annually by 15 April of the year following the reporting year (Table 2).
Rosprirodnadzor will review the completeness and accuracy of the Declaration and the Report within three months of their receipt.
New mandatory reporting
Table 2. Ecofee rates2
Group number Product groupEcofee rate, roubles
per tonne
Group 8 Wooden construction materials
From 2,025 to 9,956
Group 9 Wooden containers
Group 10 Paper and cardboard
Group 11 Household articles
Group 12 Paper stationery
Group 13 Paper and cardboard articles
Group 14 Oil products
Group 15 Tires and outside tires (for tires with an inner tube)
Group 16 Rubber articles
Group 17 Plastic packaging
Group 18 Plastic construction materials
Group 20 Sheet glass
Group 21 Hollow glass
Group 22 Barrels of iron and steel
Group 23 Lightweight metal containers
Group 28 Chargers
Group 30 Electrical lighting equipment
Group 36 Newspaper printing services
Group 35 General-purpose machinery and equipment
Group 1 Textile articles
From 11,791 to 16,304
Group 2 Carpets
Group 3 Protective clothing
Group 4 Coats and jackets
Group 5 Underwear
Group 6 Other clothing and accessories
Group 7 Knitwear
Group 24 Computers
From 26,469 to 33,476
Group 25 Communication equipment
Group 26 Electrical household appliances
Group 27 Optical equipment
Group 28 Rechargeable batteries
Group 31 Electrical household appliances
Group 32 Non-electrical household appliances
Group 34 Refrigeration equipment
2 See the ecofee rates for each of 36 groups of goods, including packaging, subject to recycling in the Government Decree No. 284 of 9 April 2016
Producers and importers can set up their own infrastructure for full-cycle waste management or separate waste management processes such as collection, sorting, transportation and recycling. It is important to note that almost all activities in hazardous waste management are currently subject to mandatory licensing.
Producers and importers may form industry associations to recycle waste (for example from a surcharge added to the price of their products or from sales of recycled products). Such associations
may deal with similar types of waste, allowing producers and importers to share the costs of recycling. However, the individual members are responsible for ineffective recycling or non-compliance, rather than the association as an entity.
Producers may outsource waste management processes to external organizations, as well as municipal solid waste (MSW) operators and regional MSW operators that perform a function similar to that of guaranteed suppliers in the power industry.
First, you need to check the applicability of the new recycling requirements. In particular, you should establish whether you manufacture or import products and/or packaging listed by the Russian Government.
You need to examine recycling options and develop a compliance plan. If your products and/or packaging are subject to recycling, you should carefully consider the following:
• Should you recycle waste or pay the ecofee to meet your waste management obligations?
• How do you plan to record the type and weight of the manufactured/imported products and packaging subject to recycling and how should you refl ect them in your report?
• How do you plan to confi rm that the data in your reports is accurate?
• How should you formalize relations with contractors to be able to confi rm compliance with the recycling obligation?
• Should you enter into an association with other manufacturers/importers?
• What are the effi cient and legal options for your business to recycle waste following the use of products and packaging?
Recycling options
How to comply? Recommended stepsStep 1. Step 2.
ContactsGeorgy KovalenkoPartner, Legal Group Tel.: +7 (495) 287 [email protected]
Yulia TimoninaPartner, Head of CIS Global Compliance and Reporting GroupTel.: +7 (495) 755 [email protected]
Anna GusevaPartner, Transaction Advisory Services Group Tel.: +7 (495) 641 [email protected]
Vadim KovalevSenior Manager, Business Tax Services Group Tel.: +7 (495) 664 [email protected]
Natalia AristovaManager, Legal GroupTel.: +7 (495) 641 [email protected]
Armine PavleyanManager, Global Compliance and Reporting GroupTel.: +7 (495) 755 [email protected]
EY has been advising clients on compliance with waste recycling legislation over the last 4 years. Our cross-service line team provides a full range of waste management advisory services, including:
• Methodological support on the interpretation of legislative requirements, analysis of their implications for business, identification of gaps in records management for products and packaging subject to recycling and recommendations on how to improve them
• Assistance with mandatory reporting, including the collection, processing and analysis of information on the type and weight of products and packaging subject to reporting using an EY developed automated tool
• Automatization of the reporting processes for mandatory reporting, including the collection, processing and storage of information on manufactured/imported products and packaging
• Analysis of markets (of certain types of waste and waste recyclers)
• Financial modeling and comparison of recycling options (using the company’s own resources, joining an association, contracting an operator/a specialized organization) with paying the ecofee
• Legal support for establishing a producers’/importers’ association, assistance with developing its organizational, corporate and operational structure to balance the interests of its members and ensure the association performs well, assistance with determining the terms of cooperation and drafting agreements between the association and its members
• Assistance with drafting producers-association, producers-operator and association-operator agreements, and support for negotiations with operators/specialized organizations.
How we can help
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