Law Messenger
Extended producer responsibility (EPR): what has changed since 1 January 2026 and how it affects businesses
14.01.2026
1. Amendments to Federal Law No. 89-FZ of 24 June 1998 “On Production and Consumption Waste” and other legislative acts
Federal Law No. 495-FZ of 28 December 2025 “On Amendments to Article 29¹ of the Federal Law ‘On Production and Consumption Waste’ and Certain Legislative Acts of the Russian Federation” (“Law No. 495-FZ”) was enacted on 31 December 2025 to introduce the new EPR[1] transition timeline for importers from non-EAEU countries.
The law implements the key amendment proposed by the draft law of the Russian Ministry of Natural Resources and Environment (the “Draft Law”) published in October 2025 (see the previous alert): the EPR pilot project is extended by two years—to 1 January 2028, replacing the original end date of 1 January 2026. The pilot procedure was changed accordingly by Russian Government Decree No. 2228 of 30 December 2025.[2]
Certain provisions of the Draft Law (e.g., a 90-day deferral of environmental fee payments instead of payments before goods are released for domestic consumption, and exclusion of guarantee agreements with recyclers) were not included in the final versions of the legislative acts. At the same time, on 11 January 2026, the Kommersant newspaper reported that the Ministry of Natural Resources and Environment had drafted a government decree to freeze adjustment multipliers for environmental fees at the 2025 level,[3] which signals potential stabilization of financial burden on businesses under the EPR framework.
The key change introduced by Law No. 495-FZ: transitional provisions will continue to apply to importers from non-EAEU countries until 1 January 2028.
The pilot project initial end date of 1 January 2026 and other special timelines established by Article 7 of Federal Law No. 451-FZ of 4 August 2023 “On Amendments to the Federal Law ‘On Production and Consumption Waste’ and Certain Legislative Acts of the Russian Federation” were amended by Article 4 of Law No. 495-FZ.
Importers from non-EAEU countries will continue to follow the transition procedure until 1 January 2028. Different requirements apply during the transition period based on whether or not imported goods and packaging are covered by the pilot scheme of the Ministry of Natural Resources and Environment.[4]
For goods and packaging not covered by the pilot scheme:
- Environmental fee reports are submitted annually, before 15 April of the year following the reporting year.
- Environmental fee is paid for a calendar year, before 15 April of the year following the reporting year.
For goods and packaging covered by the pilot scheme:[5]
- Environmental fee is reported and paid separately for each shipment before it is cleared by customs.
- Environmental fee is paid before the goods are released by the customs authorities.
Law No. 495-FZ became effective on 31 December 2025 after its official publication.
2. Amendments to Russian Government Decree No. 750 of 1 June 2024
Government Decree No. 750 of 1 June 2024 “On the Pilot Scheme for Certain Groups of Goods, Including Packaged Goods” was amended by Government Decree No. 2228 of 30 December 2025 to align the pilot scheme with Law No. 495-FZ governing the transition period.
3. Provisions of the Draft Law NOT INCLUDED in the enacted regulations:
Federal Law No. 495-FZ of 28 December 2025 and the Russian Government Decree of 30 December 2025 did not implement all the provisions of the Draft Law of the Ministry of Natural Resources and Environment. The following proposed measures have not been adopted yet:
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1. Transition to a 90-day deferral of environmental fee payments
The Draft Law contemplated revising the environmental fee payment mechanism for goods covered by the pilot scheme, namely, shifting from payments before customs release to a 90-day deferral from the release date. This provision has not been incorporated in Law No. 495-FZ. Importers will continue to pay the environmental fee either before customs clearance (for goods covered by the scheme) or at the end of a calendar year (for other goods and packaging).
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2. Exclusion of guarantee agreements as a method of securing obligations
The Draft Law proposed to limit permitted methods of securing the importer’s obligations, specifically, by excluding guarantee agreements with recyclers included in the state register. This provision has not been incorporated in Law No. 495-FZ, therefore, obligations may still be secured by guarantee agreements, along with bank guarantees and other methods permitted by law.
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3. Clarification of the status of packaging manufacturers employing specific technological processes
The Draft Law provided clarifications on the status of manufacturers that produce packaging by heating, extrusion or cutting pre-fabricated packaging materials (e.g., blow molding PET bottles from preforms). These provisions have not been adopted, therefore, legislation still lacks clarity in the identification of an EPR entity in such cases: it is unclear who must pay the environmental fee—the producer of source material (preforms) or the entity carrying out the technological process (blow molding).
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4. Additional grounds for denying inclusion in the register of recyclers
The Draft Law specified additional grounds for denying inclusion of an entity in the state register of waste disposal facilities or for removal from the register (specifically, submission of inaccurate information or failure to comply with licensing requirements for handling waste of hazard classes I–V). These provisions have not been incorporated in Law No. 495-FZ, and the existing requirements for recyclers remain in effect.
The above measures may be implemented through subsequent legislative changes, therefore, businesses should monitor all the relevant regulatory initiatives in the future.
4. Environmental fee rate discussions still underway
Federal Law No. 495-FZ of 28 December 2025, which extends the pilot project till 1 January 2028, was adopted amid ongoing debate on environmental fee rates for 2026-2027.
The base fee rates for 2025-2027 were established by Russian Government Decree No. 1041 of 1 August 2024. They are set to increase year-on-year by 15%, 8% and 4% in 2025, 2026 and 2027, respectively.
At the instruction of the Russian President,[6] the Russian Ministry of Natural Resources and Environment prepared a draft government decree[7] in August 2025 to increase environmental fee base rates several-fold starting from 2026 (3- to 18-fold, depending on the product and packaging category).
The business community called the proposed increase “unprecedented” and warned that it would lead to product price spikes. Russia’s Ministry of Industry and Trade argued against such a drastic rise that may put a significant pressure on businesses.[8]
At the cabinet meeting of 1 October 2025, Deputy Prime Minister D. Patrushev spoke against sharp increases in environmental fee base rates, with the majority of the concerned ministries backing his stance.[9]
On 11 January 2026, Kommersant reported that the Russian Ministry of Natural Resources and Environment prepared a draft government decree freezing adjustment multipliers for environmental fees for 2026 at the 2025 level.[10]
The regulator, businesses and the relevant ministries continue discussions about the economically viable level of environmental fee rates.
5. Higher environmental fee factor for tires not compliant with GOST (Russian Government Decree No. 2116)
Russian Government Decree No. 2116 of 25 December 2025 was enacted on 1 January 2026, making sweeping changes to collecting environmental fees on tires.
Key changes are summarized below.
From 1 January 2026, the technological recyclability factor (Ftechn) of 17 applies to tires that are not certified for compliance with clause 4.2 of GOST R 51893-2024 “Pneumatic tires. General technical safety requirements” (requirements for carcinogenic safety of materials). Ftechn for certified products is zero.
Tire categories to which Ktechn applies:
- New pneumatic passenger tires (OKPD2 code: 22.11.11.000)
- Pneumatic tires for motorcycles, microcars, motor scooters, mopeds (OKPD2 code: 22.11.12.110)
- New pneumatic tires for buses, trolleybuses and trucks (OKPD2 code: 22.11.13.110)
Exception: semi-steel tires with textile carcass and metal cord breaker, with load index over 121 per tire.
Government Decree No. 2116 also amends a number of other government decrees (GD), as follows:
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GD No. 1958 of 31 December 2019 (tire marking rules)[11]
New mandatory information was added: tire structure type (for TN VED code 4011 20 900 0); number and issuance date of the certificate of compliance with GOST R 51893-2024 (if any).
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GD No. 868 of 13 May 2022 (regulation on the unified waste accounting system)[12]
Columns 12 and 13 were added in the reporting form for marked goods (Annex No. 11): information about permits (certificates/declarations of conformity) and additional information (tire structure type and load index for TN VED code 4011 20 900 0).
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GD No. 1041 of 1 August 2024 (base rates and factors for calculating environmental fees)[13]
Ftechn of 17 applies to group 5 (tires, tire casings, rubber inner tubes).
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GD No. 1990 of 30 December 2024 (environmental fee collection rules)[14]
A requirement was introduced to specify GOST-certified goods separately from non-certified goods in environmental fee reports.
The existence of certificates of compliance is verified automatically through the integration of the unified waste accounting system with the national track & trace system. Certificates must be issued by certification bodies accredited with the national accreditation system.
Given the above, the environmental fee on tires is calculated as follows:
EF=BR×(Fcompl+Ftechn)×Qrecycl×W
where:
- EF – environmental fee amount (RUB)
- BR – environmental fee base rate (RUB/t)
- Fcompl– waste collection complexity factor (18 for tires)
- Ftechn– technological recyclability factor (0 for GOST-certified goods; 17 for non-certified goods)
- Qrecycl – recycling quota (for tires: 55% in 2026, 60% in 2027)
- W – weight (t)
The increase in environmental fees will potentially result in proportionally higher administrative fines. For reference, clause 8.41.1 of the Russian Administrative Offenses Code provides that failure to pay the environmental fee by the due date results in a fine equal to three times the amount owed, but not less than RUB 500,000 for legal entities. According to clause 8.5.1 of the Russian Administrative Offenses Code, filing inaccurate reports leads to a fine equal to twice the amount of the fee owed, but not less than RUB 250,000 for legal entities.
Recommendations
We recommend that importers bringing goods and packaging from non-EAEU countries take the following measures:
- Review the current EPR compliance processes, including documentation, calculation and payment of environmental fees, execution of guarantee agreements and compliance with reporting deadlines
- Continue monitoring any regulatory changes and start preparations for transitioning to the new procedure
Tire manufacturers and importers may take further steps:
- Check whether the imported/manufactured tires are certified to GOST R 51893-2024
- For non-certified products, assess whether it would be more practical to obtain certification from an accredited body or to switch to certified products, given the twofold difference in the environmental fee
- Enter accurate information about the certificate of compliance in the track & trace system to automatically import data to the unified waste accounting system and qualify for the zero Ftechn
How B1 can help
B1 offers a comprehensive suite of EPR services:
- EPR compliance check (including the previous reporting periods), development of a fee calculation methodology tailored to the company’s products and packaging and review of compliance with transitional provisions and the pilot scheme terms
- Assistance in preparing and submitting EPR reports to the unified waste accounting system
- Support in liaising with government authorities on EPR matters, including the preparation of requests for additional information from the Russian Federal Customs Service, Rosprirodnadzor and the Russian Ministry of Natural Resources and Environment, representing the company during audits
- Assistance in selecting recyclers included in the state register of waste disposal facilities and entering into contractual arrangements, verification of their compliance with licensing requirements
- Set-up of EPR processes and development of automated solutions to manage the reporting process, track shipments of goods and packaging, calculate environmental fees, generate declarations and integrate the software with the unified waste accounting system
Show references
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[1] EPR transition is a temporary regime for importers from non EAEU countries, introduced in 2024 as a pilot. It applies only to certain types of goods and packaging and changes when environmental fees must be reported and paid compared to the usual annual approach. The EPR transition currently applies until 1 January 2028.
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[2] Постановление Правительства Российской Федерации от 1 июня 2024 г. N 750 «О проведении эксперимента в отношении отдельных групп товаров, в том числе товаров в упаковке»
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[4] Переходный порядок для импортеров из государств, не являющихся членами ЕАЭС, установлен статьей 7 Федерального закона от 04.08.2023 № 451-ФЗ «О внесении изменений в Федеральный закон «Об отходах производства и потребления» и отдельные законодательные акты Российской Федерации» (в редакции Федерального закона от 29.12.2025 № 495-ФЗ). Порядок проведения эксперимента в отношении отдельных групп товаров определен Постановлением Правительства РФ от 01.06.2024 № 750 (в редакции Постановления Правительства РФ от 30.12.2025)
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[5] В Перечень отдельных видов товаров, в том числе товаров в упаковке, участвующих в эксперименте (Приложение № 1 к Постановлению Правительства РФ от 01.06.2024 № 750), включены: одежда и изделия текстильные - группа № 1 (код ТН ВЭД ЕАЭС 6103 49 000 1); шины, покрышки, камеры резиновые и изделия из резины прочие - группа № 5 (коды ТН ВЭД ЕАЭС 4011 10 000, 4011 20, 4011 40 000 0, 4011 50 000, 4011 80 000 0, 4011 90 000 0); стиральные машины бытовые (за исключением машин для прачечных) - группа № 10 (код ТН ВЭД ЕАЭС из 8450); аккумуляторы свинцовые - группа № 12 (коды ТН ВЭД ЕАЭС 8507 10, 8507 20); изделия пластмассовые упаковочные из полипропилена - группа № 25 (код ТН ВЭД ЕАЭС 3920 20 210 9); тара и изделия упаковочные из металла - группа № 31 (код ТН ВЭД ЕАЭС 7612 90 800 1); тара и изделия упаковочные из комбинированных материалов на основе бумаги - группа № 32 (код ТН ВЭД ЕАЭС 4811 51 000 9)
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[11] Пункт 1 Постановления № 2116
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[12] Пункт 2 Постановления № 2116
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[13] Пункт 4 Постановления № 2116
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[14] Пункт 5 Постановления № 2116
AUTHORS
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Natalia Aristova
B1 Partner
Legal Services. Expert in corporate, finance and banking law, sanctions compliance, energy and environmental law
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Larissa Gorbunova
B1 Partner
Business Tax Compliance, Tax, Law and Business Support
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Vladislav Ovsyannikov
B1 Manager
Business Tax Compliance, Tax, Law and Business Support
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Iaroslav Solarev
B1 Manager
Legal Services
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