On 1 January 2025, new rules* governing the collection of environmental fees came into force. Producers of goods and packaging, as well as importers of goods (including packaged goods) who fail to ensure the disposal of waste from such goods and packaging in accordance with established norms*, must calculate and pay the environmental fee for 2024 under the new procedure via the waste accounting system (EFGIS UOIT).

As before, the environmental fee must be calculated and paid by 15 April, except for importers from non-EAEU countries participating in the experiment*, who, as a rule, must pay the fee before customs clearance of imported goods.

Previously, the Government approved* base rates of environmental fees for each group of goods and packaging for 2025 - 2027, along with special coefficients that reflect the complexity of waste extraction and the technological feasibility of waste utilisation from the use of the goods concerned.

When calculating environmental fees, a reduction factor* may be applied to the established recycling rate, reflecting the share of secondary raw materials used in the production of the relevant goods. However, in order to qualify for this reduction, manufacturers must formally confirm their technical and technological capability to produce goods using secondary raw materials, in accordance with established procedures*.

In addition, the weight of goods and packaging exported from the Russian Federation may be excluded from the environmental fees’ calculation. However, exporters must provide confirmation of such exports, in line with the approved rules*.

Instead of paying the environmental fee, companies may sign a waste disposal contract with a registered recycler. However, regulatory control over such contracts is expected to increase.

The fines for violating reporting procedures and failing to pay the environmental fee remain unchanged: for reporting violations, they can reach up to twice the amount of the unpaid fee and for non-payment of the environmental fee – up to three times the amount due. However, a key change is that supervisory authorities can now initiate administrative cases without conducting inspections and, thus, impose fines automatically.

Given these regulatory changes, it is strongly recommended that all producers and importers subject to extended producer responsibility:

• Strictly comply with the established rules when submitting annual reports and calculating and paying the environmental fee.
• If choosing waste disposal contracts instead of the environmental fee, ensure that the recycling company provides confirmation of actual waste utilisation in the agreed volumes.

*In Russian

The material is also available in Chinese and Russian.