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Extended Producer Responsibility in Russia

Extended Producer Responsibility in Russia

Lisa Dean Profile Image
by Jordan Girling, May 2016
Jordan is EC4P’s EU Compliance Team Lead where he helps companies identify their legal exposure to WEEE, Batteries and Packaging legislation and provides cost-effective and legally-robust recommendations for compliance.

Russia is not a member of the European Union and has no obligation to transpose the requirements of the EU WEEE Directive, EU Batteries Directive or the EU Packaging and Packaging Waste Directive. However, Russia is able to implement legislation containing requirements similar to those of EU Member State national regulations.

An amendment to the Russian 1998 ‘Federal Law on Waste from Production and Consumption’, which entered into force in January 2015 placed take-back (i.e. collection and recycling) obligations on producers and importers of certain products and packaging.

On 24 September 2015, Government Order 1886-p/2015 specified a comprehensive list of products and packaging falling within the scope of the new take-back requirements specified in the Federal Law amendment. The scope list firstly groups products and packaging into 36 different groups, numbered by codes under the national system of classification of products by economic activity (ОК 034-2014 (КПЕС 2008)). Products within these 36 groups are then arranged by common product name, as well as product code and nomenclature according to the EAEU Harmonised System of product classification (EAEC HS). Changes and additions to the list can be proposed by the Ministry of Natural Resources and Ecology. Groups applicable to EEE are detailed below:

  • (No 24) Computers and peripherals
  • (No 25) Communications equipment
  • (No 26) Consumer electronics
  • (No 27) Optical devices and photographic equipment
  • (No 30) Electric lighting equipment
  • (No 31) Household electric devices
  • (No 32) Non-electric household devices
  • (No 33) Power-assisted hand tools
  • (No 34) Industrial refrigeration and ventilation equipment
  • (No 35) General purpose machinery and equipment, not included in other categories

Mandatory collection rates for products and packaging in scope of the Federal Law amendment are to be set every three years. To meet take-back obligations for certain products within the scope of the requirements stipulated in the Federal Law amendment, producers and importers must either:

  • Establish their own waste management infrastructure;
  • Form collective organisations to manage waste;
  • Enter into contracts with regional operators; or
  • Pay the Environmental Fee

In reality, paying the Environmental Fee is seen as a method of compliance rather than a punishment for non-compliance. Furthermore, the fees payable are based on the average cost of collection, transportation and disposal of each product; therefore, paying the Environmental Fee is a financially attractive option and has a relatively low administrative burden.