Russia: EPR – Clarified which products are to be reported as subject to the extended producer responsibility

As of 4 August 2018, manufacturers and importers of products subject to the extended producer responsibility (EPR) are required to follow the revised reporting procedure of products subject to the EPR.

The amendments to the existing procedure clarify, that It was established, in particular, when an importer or manufacturer draws up a declaration on the quantity of goods or packaging subject to the EPR that they have released on the Russian market during a calendar year, they should not include the following goods into the declaration (report):

  • goods that have been exported from the Russian Federation; and
  • packaging of goods exported from the Russian Federation.
  • Manufacturers of goods should include into their yearly declaration (report):
  • goods produced in the Russian Federation;
  • packaging of goods produced in the Russian Federation.

Importers of goods must include into their yearly report:

  • goods imported from the member states of the Eurasian Economic Union;
  • customs cleared goods imported from any third countries into the Russian Federation;
  • packaging of goods imported from the member states of the Eurasian Economic Union;
  • customs cleared packaging of goods imported from third countries into the Russian Federation.

Reusable packaging of goods must be reported as a finished product.

Producers of goods must include in their declarations (yearly reports) information on the quantity of goods (packaging of goods) based on the content of their primary accounting documents.

Importers of goods must include in their yearly reports information on the quantity of goods (packaging of goods) on the basis of the information contained in the relevant customs documents and other accompanying documents.

In addition, the revised procedure sets out a form for a yearly report on the quantity of goods released into circulation in the Russian Federation and packaging of goods subject to the extended producer responsibility.

Law: Decree No. 868 of 25 July 2018, on Amending Decree No. 1417 of 24 December 2015