Extended producer responsibility

Ukraine: Extended Producer Responsibility (EPR) overview

The extended producer responsibility (EPR) framework in Ukraine has been introduced by the revised Law on Wastes (enters into force in July 2023). 

The responsible producers have to fulfil their EPR obligations either collectively – by joining a compliance scheme or individually – by setting up their own compliance system.

The EPR in Ukraine includes the following:

Moldova: the Extended Producer Responsibility (EPR) Framework

The extended producer responsibility (EPR) framework in Moldova is set out in the Law on Wastes No. 209. This law partially transposed the provisions of the EU Waste Framework Directive 2008/98/EC into the national legislation.

According to the Law on Wastes, the following products are to be subject to the EPR obligations:



a)      Batteries and accumulators;

Georgia: Amended regulations on waste oils management

As of 20 September 2022, changes to the waste oils management rules entered into force in Georgia.

The changes exempt the following types of oils from the scope of the waste oil management regulation:

a) oils imported by a natural person (except for an individual entrepreneur / sole trader);

b) oils declared for import by the state body of a foreign country and/or international organization;

c) oils declared for import for the purpose of humanitarian aid or as a grant;

Russia: The EPR reform postponed

Russia has postponed the adoption of the regulatory framework for the reformed extended producer responsibility (EPR) system to the end of 2022 which means that the revised system is to be operational as of 2023.

Initially, it was intended to introduce the reform in early 2022. The reform would have imposed the obligation on manufacturers and importers to recycle or reuse (“utilise”) 100% of packaging they place on the Russian market.

Russia: Revised rules for the submission of EPR reporting

As of 1 January 2021, importers and manufacturers of products subject to the extended producer responsibility (including electrical and electronic equipment, batteries, textiles and packaging) as well as manufacturers’ associations are required to submit the relevant yearly reporting in accordance with the revised procedure.  The report must contain information about products released on the Russian market during reporting year, the fulfilment by a particular importer or manufacturer of the set utilisation / recycling targets for wastes that in

Russia: EPR – adopted recycling targets for 2021

Russia has adopted recycling targets for 2021 for wastes generated from products subject to the extended producer responsibility (EPR) requirements (including WEEE, batteries and packaging wastes).

Russia: EPR – Form and submission rules for the environmental charge calculation

Importers and manufacturers of products subject to the extended producer responsibility (EPR) and recycling targets (e.g. electronic equipment, textiles and some types of packaging) will have to submit the environmental charge calculation form in accordance with the rules adopted by Order No. 920 of 13 July 2020.

KAZAKHSTAN: Revised Rules for the Extended Producer Responsibility (EPR)

Manufacturers and importers pf products subject to the extended producer responsibility in Kazakhstan are required to comply with the revised version of the Rules on EPR obligations, including management of waste electrical and electronic equipment (WEEE), batteries and packaging.

The EPR obligations arise:

-          For manufacturers – from the moment a finished product has been recorded as such in the manufacturer’s internal records;