For manufacturers · April 14, 2026
TR CU 005/2011: documents for packaging and model media
Who the applicant is, why model media are used, and why the environmental fee is a separate duty.
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11 min
The environmental fee is an obligation that most sellers learn about not from the law but from a payment demand. It is not connected with conformity confirmation: the documents for the product may be in perfect order while the recycling reports are not submitted for years. We will look at who exactly falls under extended producer responsibility, what the amount consists of and what is submitted in reporting.
What EPR is and why it is not about ecology
Extended producer responsibility (EPR) is a principle under which the one who put goods or packaging into circulation is responsible for their fate after the buyer has used them. The state does not require you to collect waste personally. It requires that the corresponding volume be recycled — by you, by a hired recycler or, if neither, by money.
Hence the logic of the whole construction: first it is calculated how much goods and packaging you have put into circulation, then what share of this is subject to recycling, and only then do you get a choice of how to meet the obligation.
Who is obliged and for what exactly
Responsibility is distributed not by who sells, but by who first puts the products into circulation in the territory of the country.
| Who | What they are responsible for |
|---|---|
| Manufacturer of goods | For the goods themselves from the list of goods subject to recycling |
| Manufacturer of packaging | For the packaging that it produced and sold to others |
| Importer | Both for the imported goods and for the packaging in which they were imported |
| Seller on a marketplace | If the seller is also the importer or the manufacturer — for both; if it resells goods bought in the country — the obligation lies with the one who put them into circulation |
The key shift of the latest reform concerns packaging: responsibility for it has moved to the one who produces the packaging, not to the one who puts something into it. For the importer this does not simplify anything — it imports the goods already packed, so it is responsible for both items at once.
A common misconception
“We buy packaging from a Russian factory, so it is the factory that reports on it.” This is true for packaging that you bought empty inside the country. But everything that arrived from abroad together with the goods is your area of responsibility, and the supplying factory has nothing to do with it.
Three ways to meet the obligation
- Recycle on your own. Suitable for producers that have their own capacity or a stable turnover of secondary raw materials.
- Conclude a contract with a recycler. The most common way. The recycler must be in the register — certificates from an organisation without a confirmed status do not meet the target.
- Pay the environmental fee. The default way: if the target is not met by either of the first two ways, the difference is covered with money.
The ways can be combined: part of the volume is covered by recycling certificates, the remainder by the fee. It is only important that together they make up the required target.
What the amount consists of
The calculation is based on three values, and an error in any of them breaks the result.
- Mass. How much goods and packaging was released or imported during the reporting year, in tonnes and by group.
- Recycling target. The share of this mass that must be recycled. It is different for different groups.
- Fee rate. It is approved by the government separately for each group and is revised periodically.
The practical conclusion: the main work is not in the calculation but in the records. The mass of packaging by type of material (cardboard, polymer, glass, metal, combined) must be known as a fact, not estimated afterwards. This is easiest to do at the specification stage: the weight of the container is recorded at the same time as the container itself is agreed.
What is submitted and when
| Document | What it is about |
|---|---|
| Declaration of released goods and packaging | What was put into circulation during the year and in what volume |
| Report on meeting the target | How the target was met: by recycling certificates or by the fee |
| Calculation of the amount of the fee | The total by groups, if the target was not fully met |
The reporting period is the calendar year, and reporting and payment fall in the spring of the next year. Everything is submitted through the state information system; the paper version remained only for certain cases. The exact deadlines and forms should be checked against the current version of the rules: over the last years they have changed more often than anything else in this area.
Where the targets are heading
The general direction is set and not under discussion: the recycling target for packaging is raised in steps and reaches the full volume — that is, as much will have to be recycled as was released. For planning this means that the costs under this item will grow in the coming years by definition, and budgeting them “as last year” is wrong.
The practical answer to the growth of the target is not only money. Reducing the mass of packaging, giving up combined materials that are hard to recycle and switching to single-material packaging reduce the calculation base. This is the only lawful saving that works in the long run.
What it threatens if you do not report
Liability here is arranged more unpleasantly than in most related areas: the fine is calculated not as a fixed amount but as a multiple of the unpaid fee. That is, the longer the obligation has not been performed and the larger the turnover, the larger the result. Failure to submit reports is punished separately — even if the amount due itself is zero.
Add to this that customs has the data on import, and the enterprise’s reporting has the data on the release of products. Comparing them is not difficult, and “they will not find us” is a poor strategy for a business that plans to grow.
How this is connected with the documents for the product
Formally — not at all: these are two different obligations, and having a declaration of conformity does not cancel recycling reports. In practice, though, they share an entry point. In both cases everything starts with your understanding exactly what goods you bring in: the HS code (TN VED), the type and material of the packaging, the composition of the delivery. A company that has put the description of its range in order once handles both tasks almost without additional effort.
The most sensible moment to do this is the launch of a new product, when the specification has not yet gone into production and the weight of the container can be changed without losses.
Typical errors
- They count only consumer packaging and forget transport packaging — boxes, pallets, stretch film
- They take certificates from a recycler that is not in the register and find this out only during a check of the reports
- They keep records in pieces although the calculation is in tonnes — the weight of the container has to be reconstructed afterwards
- They do not submit a zero report, believing that when there is no obligation there is nothing to submit
- They plan the budget using last year’s rate, not taking into account the growth of the target
- The importer relies on the reporting of the foreign supplier, which means nothing in the Russian system
Order of actions
- Determine whether your product is on the list of goods subject to recycling and which packaging groups you use.
- Collect the data for the reporting year: volumes of release or import, weight of packaging by type of material.
- Decide how you will meet the target: by a contract with a recycler, by your own recycling or by the fee.
- Check the recycler against the register before signing the contract, not after receiving the certificates.
- Submit the declaration and the reports on time, even if the amount due is zero.
- Include the growth of the target in next year’s budget and at the same time look at where the packaging can be made lighter.
Check your product
Describe your product in plain words — the system will show the applicable regulations, the form of confirmation and the set of documents, so that the mandatory requirements do not come up one by one. Start the check.
