The Russian extended producer responsibility system receives additional clarification, which is important for all participants in foreign economic activity. Rosprirodnadzor has officially confirmed that when importing goods, the obligation to pay an environmental fee and submit reports is assigned to the importer, regardless of the subsequent transfer of ownership.
The situation that has raised questions among businesses looks typical. The company imports the goods into Russia, registers them for itself, and then resells or transfers them to another legal entity. In such schemes, market participants tried to understand who exactly should comply with the requirements of the ROP.
The regulator's position is clearly formulated. The key criterion is the fact of import and the status of the declarant. If the company is listed in the customs documents as the person who imported the goods, it is responsible for waste disposal and payment of the environmental fee.
Reporting is based on customs declarations and shipping documents. This means that control is tied to the primary entry point of the product into the country, and not to subsequent transactions within the market.
For businesses, this solution removes uncertainty, but at the same time increases the requirements for importers. Now it is impossible to transfer obligations to the next participant in the chain after the sale of goods. All environmental obligations are recorded at the time of importation.
Special attention should be paid to deadlines. It is necessary to submit the EPR reports and pay the environmental fee by April 15. For companies, this means the need to verify data on import volumes, packaging, and product categories in advance, as well as ensure that all documentation is correct.
The practical conclusion for foreign economic activity is obvious. Importers need to set up accounting in such a way that each batch of goods is correctly reflected in the reports, and the calculations for the eco—collection are justified and documented. Otherwise, the risks of claims from the regulator increase.
As a result, Rosprirodnadzor establishes the principle that responsibility for the environmental footprint of imported goods begins from the moment it is imported and remains with the declarant.
