A clarification letter issued by the Federal Service for the Supervision of the Use of Natural Resources has issued a clarification letter explaining which facilities are not required to develop and approve waste generation and disposal limits (NOOLR).
Federal Service on the Supervision of the Use of Natural Resources (RosPrirodNadzor) which is the Russian environmental law enforcement agency has issued a clarification letter on a number of waste management issues.
As of 28 December 2017, organisations planning any activity that is subject to the environmental expert assessment (i.e. any activity that has a potentially high environmental impact) are required to comply with the revised provisions governing the performance of environmental expert assessment.
Starting from 1 January 2018 manufacturers and importers of products included into the revised list of products subject to the extended producer responsibility (EPR) obligations are obliged to comply with the utilisation targets set for such products and packaging or to pay the environmental charge.
The adopted list replaces the list adopted by Government Direction No. 1886-p dated 24 September 2015.
Starting from 2018, importers and manufacturers of products subject to utilisation targets (within the extended producer responsibility - EPR – concept) are required to comply with the revised utilisation targets.
The highest targets (25% for 2018 and 45% for 2020) have been set for corrugated paper and paperboard and corrugated paper and cardboard packaging.
The Federal Service for the Supervision of the Use of Natural Resources has clarified which legislation is to be applied by importers and manufacturers in determining their obligations within the extended producer responsibility concept (EPR).
Manufacturers and importers of products subject to recycling after the loss of their consumer properties (e.g. electronic equipment, cardboard and paper packaging and textile products) within the extended producer responsibility framework, might soon be able to submit the environmental charge calculation reports in electronic form online.
The Federal Agency on the Supervision of the Use of Natural Resources has published a clarification on handling steel used oil and gas pipes.
The Agency explained that the Federal Classification Waste Catalogue (FKKO) includes a group of wastes called “used steel oil and gas pipes”. Therefore, such used pipes are considered as “wastes” and their handling is regulated by the Federal Law on Industrial and Consumer Wastes No. 89-FZ.
A letter issued by the Russian environmental protection authority (RosPrirodNadzor) No. AC-10-02-36/13739 dated 28 June 2017, explains that it is the trademark owner who is responsible for compliance with the recycling targets or for paying the environmental charge in relation to products and packaging they have placed on the Russian market.
The Ministry of Natural Resources and Ecology has drafted amendments to the Law on Industrial and Consumer Wates No. 89-FZ. The amendments would clarify that manufacturers and importers of product components (rather than finished products) or any materials that are to be used for manufacturing other goods will not have to comply with any recycling targets within the extended producer responsibility (EPR) concept.
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