Management of waste electrical and electronic equipment (WEEE management) is gaining more and more importance all over the world. Although Russia tends to lag behind the EU in implementing environmental and waste management regulations, it has recently introduced the concept of extended producer responsibility (EPR) that imposed WEEE management obligations on manufacturers and importers of electrical and electronic equipment (EEE).
The Ministry of Natural Resources and Ecology has submitted a proposal that would impose liability on associations of manufacturers and importers to report on the fulfilment of recycling targets within concept of extended producer responsibility (EPR). Currently, only importers and manufacturers of products subject to EPR are required to submit such reports.
According to the recent clarification published by the Ministry of Natural Resources and Ecology, it is the manufacturer (importer) that sells to the end user products the use or consumption of which result in waste generation that is responsible to achieve the recycling targets.
The proposed draft Decree would add several types of products and packaging to the list of products and packaging subject to the extended producer responsibility (EPR). In particular, draft Decree would add the following types of products and packaging to the list:
The Ministry of Natural Resource and the Environment has published a Guidance explaining how extended producer responsibility (EPR) provisions are to be applied.
Russia has started public discussions on the proposed amendments relating to the extended producer responsibility concept (the EPR). The EPR requires manufacturers and importers of listed products to either organize utilization of such products (including packaging) or to pay environmental charges for the utilization.
Clarification issued by the RosPrirodnadzor (the Russian environmental authority) explains that manufacturers and importers of certain products are required to ensure utilization of the set quantities of wastes generated as a result of such products losing their consumer properties. This requirement also applies to the packaging of such products. This concept is called “extended producer responsibility” (EPR) and was initially introduced by the Federal Law of the Russian Federation on the Industrial and Consumer Wastes.
As of 28 September 2015 manufacturers and importers of certain products and packaging are formally required to either recycle wastes generated from the use of such products themselves or to sign a contract for recycling with a recycling operator.
Product manufacturers and importers will have to organize collection, treatment, transportation, use and utilization of wastes generated from the use of these products. This requirement was initially introduced by the Environmental Code of Kazakhstan. At the first stage, the requirement only applies to the automotive industry producers and manufacturers, such as those importing vehicles, tyres, accumulators, motor oils, etc.
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