Russia: EPR. Who is responsible for compliance with the recycling targets?

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.

In accordance with the legislation, the responsibility to achieve the set recycling targets (utilisation norms) lies with the manufacturers or importers of the finished products (including packaging) that are included into the list adopted by Governmental Direction No. 1886-r of 24 September 2015.

According to the Ministry of Natural Resources and the Environment, this responsibility does not arise if the products are sold to a consumer who uses these products in order to manufacture other products, and as a result, no waste is generated by these products’ use. For example, a manufacturer of paper products will not be responsible for the utilization of these products if he sells them to another manufacturer who uses them for producing printed products.

If printed products manufacturer sells these products to a consumer and as a result of consumption wastes are generated, then this manufacturer will be responsible for utilization of wastes generated as a result of this consumption.

The responsibility to achieve waste utilization targets also does not apply to organisations rendering services with the use of products included into the List but not being manufacturers of these products (e.g. organisations rendering services of newspaper publishing). However, a publishing facility may acquire this responsibility if it itself places on the market any printing products, such as newspapers or magazines.