The Ministry of Natural Resources of Russia is preparing a draft decree to increase environmental fee rates

It will be recalled that the EPR mechanism is enshrined in Federal Law No. 89-FZ of 24.06.1998 "On Production and Consumption Waste". The law requires producers and importers of goods either to ensure the recycling of a prescribed percentage of waste from products sold or to pay an environmental fee for failure to meet that level.

At present, Decree No. 1041 of the Government of the RF dated 01.08.2024 has already approved:

• Basic rates for 2025–2027 for each group of goods and packaging
• Recycling targets for that period.

By way of example, listed below are a number of items with basic rates and coefficients for 2026.

• Composite paper-based containers – basic rate of 2,953 rubles per ton; applying the complexity coefficient of 2 makes it effectively 5,906 rubles
• Clothing and textiles as goods – 20,250 rubles per ton (coefficient 1).

In this regard:

• The current rates were already supposed to be indexed gradually over 2025–2027 (by an average of 15% in 2025, 8% in 2026 and 4% in 2027)
• Targets will also increase (especially for packaging, with targets for most items rising from 55% in 2025 to 75% in 2026 and 100% in 2027)/

It will also be recalled that in 2024-2025, as part of an experiment, a new procedure for the fulfilment of EPR obligations was introduced for importers from non-EAEU countries. Under that new procedure, importers of certain groups of goods and packaging are already required, before goods are released for free circulation, either to:

• Pay the environmental fee in advance, or to
• Confirm their intention to recycle waste independently and provide a bank guarantee or surety for the appropriate amount of the fee.

In addition, for each imported consignment of goods and packaging it will be necessary to submit special EPR reports (upon importation).

From 1 January 2026, this procedure will become mandatory for all importers from countries outside the EAEU.

Failure to comply with EPR requirements brings about financial consequences in the form of fines. For example, according to Article 8.41.1 of the Administrative Offenses Code of the Russian Federation, failure to pay the environmental fee within the prescribed period is punishable by a fine imposed on the legal entity in the amount of 3 times the amount of debt, but not less than 500,000 rubles.

Business associations are continuing to engage in dialogue with regulators about the proposed reform. Individual companies are also encouraged to engage with industry associations to consolidate their positions and participate in discussions regarding the proposed changes.

• Checking compliance with EPR requirements (including for previous reporting periods) and preparing a methodology that takes full account of the characteristics of a company's goods and packaging
• Preparation and submission of EPR reports
• Support in interaction with government authorities on EPR issues, including the drafting and submission of follow-up inquiries.