The Tyre Manufacturers Association, together with other business associations sent an address to the Minister of Natural Resources and Environment of the Russian Federation, Sergey Donskoy, dedicated to one of the key challenges of implementing the responsibility for the recycling of waste from the use of the goods.

The new responsibility was introduced by Federal Law “On Production and Consumption Waste” (amended by Laws 458-FZ of 29.12.2014 and 404-FZ of 29.12.2015). Companies have the opportunity to select the method of performance of the responsibility: They can pay an environmental fee to the federal budget, but they also can recycle the waste themselves. This includes employing contractors or a specifically-created branch union for this purpose. The state thus sets targets for recycling which determine the quantity of certain products that must be recycled during the year. To calculate the amount of their liability, manufacturers and importers have to multiply the recycling norms, approved in percentage, by the volume of the goods released onto the market. The following issue is of fundamental importance, especially for the self-fulfilment of the obligation: data on which specific year of release into circulation should be used to determine the responsibility of the manufacturer in the reporting year. For example, to calculate the responsibility for 2016, should the targets established in 2016 be multiplied by the volume of production of new products in 2015 or in 2016?

Business associations ask the Ministry of Natural Resources and Environment of the Russian Federation to confirm the operation mechanism, according to which one should calculate the manufacturer’s responsibility according to the recycling norms established by the Government of the Russian Federation multiplied by the volume of the previous release of the goods, rather than the current year, i.e., targets for 2016 are multiplied by the production volumes in 2015. This is consistent with the international approach and is convenient for manufacturers and recyclers, as it allows them to work with specific data rather than estimates and enter into meaningful contracts with recyclers.