As of 4 August 2018, manufacturers and importers of products subject to the extended producer responsibility (EPR) are required to follow the revised procedure of annual reporting of products and packaging placed on the Russian market.
The amendments to the existing procedure clarify that the goods and packaging exported from Russia are not to be included into the total quantity of reported products.
The amendments also make it clear that producers must report all relevant products and packaging manufactured in Russia. Importers must report all relevant products and packaging imported from the other EAEU member states as well as those imported from the third countries.
If a company or a sole trader is acting both as the importer and manufacturer, they should submit the declaration (report) to the same state agency as those who act as importers only – to the central office of the Federal Service of the Supervision of the Use of Natural Resources (RosPrirodNadzor). Manufacturers should submit their reports to the relevant local (territorial) office of RosPrirodNadzor.
The amendments clarify that multiple use packaging must be reported as a product and not as packaging.
RosPrirodNadzor will check the accuracy of information provided in each report (“declaration”) on the quantity and types of goods placed on the Russian market within three months from the date the report was accepted.
Law: Decree No. 868 of 25 July 2018 on Amending Decree No. 1417 of 24 December 2015