Calculation and payment of the environmental fee for 2016

Article 24.2 of Federal Law No. 89-FZ of 24.06.1998 "On Production and Consumption Waste" establishes the obligation of producers and importers of goods to ensure the disposal of waste from the use of these goods. 

Decree of the Government of the Russian Federation No. 1886-r dated 24.09.2015 established a list of finished goods, including packaging, which are subject to disposal after they lose their consumer properties (groups of relevant goods are listed below).

It is worth noting that the obligation to dispose of packaging is imposed on manufacturers and importers, regardless of the inclusion of goods in this list. 

Manufacturers and importers have several ways to ensure the disposal of waste from the use of goods: 

organize your own infrastructure for the collection, processing and disposal of waste;
conclude an agreement with organizations that are engaged in the collection, transportation, processing, and disposal of waste;
create an association (union) of producers (importers) of goods to carry out waste disposal activities.

Please note that manufacturers and importers of goods that do not ensure waste disposal are required to pay an environmental fee. When paying the environmental fee, it is also necessary to submit a calculation of its amount (the calculation form was approved by the Order of Rosprirodnadzor No. 488 dated 08/22/2016).

The settlement period for the payment of the environmental fee is a calendar year. Manufacturers and importers of goods must submit the relevant reports for 2016 in the following terms:

1) until April 1, 2017: 
declaration on the number of finished goods put into circulation in the territory of the Russian Federation, including packaging (in accordance with the list approved by the Government of the Russian Federation);
reporting on the implementation of standards for the disposal of waste from the use of goods (standards approved by the Decree of the Government of the Russian Federation dated 04.12.2015 No. 2491-r).

2) until April 15, 2017:
calculation of the amount of the environmental fee (it is also necessary to pay the fee).

In some cases, manufacturers and importers do not have the obligation to submit reports and pay an environmental fee: 
if finished goods, packaging of goods are imported not for the purpose of selling to consumers, but for their own needs;
if the manufactured packaging is sold (sold as a finished product) to another manufacturer in order for the latter to use this packaging for its own manufactured products.

Please note that failure to submit reports, as well as non-payment of the environmental fee may entail liability provided for by the legislation of the Russian Federation.

We recommend that you evaluate the need for reporting and payment of an environmental fee by your company. If you have any additional questions, our lawyers are ready to advise you and provide the necessary support. 

List of groups of finished goods to be disposed of after their loss of consumer properties:

1. Finished textile products (except clothing)
2. Carpets and carpet products 
3. Workwear 
4. Other outerwear 
5. Underwear 
6. Other clothing and accessories 
7. Knitted and crocheted other garments 
8. Other wooden construction and joinery products 
9. Wooden container 
10. Corrugated paper and cardboard and paper and cardboard containers;
11. Household and sanitary products and toiletries
12. Stationery paper supplies 
13. Other paper and cardboard products 
14. Petroleum products 
15. Tires, tires and rubber chambers; restoration of treads and rubber tires;
16. Other rubber products 
17. Plastic packaging products 
18. Plastic construction products 
19. Other plastic products
20. Bent and processed sheet glass
21. Hollow glass
22. Barrels and similar containers made of ferrous metals
23. Light metal packaging
24. Computers and peripheral equipment
25. Communication equipment
26. Household electronic appliances
27. Optical devices and photographic equipment
28. Batteries
29. Rechargeable batteries
30. Electric lighting equipment
31. Household electrical appliances
32. Household non-electric appliances
33. Manual tools with mechanized drive
34. Industrial refrigeration and ventilation
equipment 35. General purpose machinery and equipment, other, not included in other groupings
36. Newspaper publishing services