Dear colleagues,

Last autumn we provided you with the overview of the current regulation and upcoming changes regarding environmental fee reporting and payment terms – more information can be found here.

As a reminder, one of the changes we recommend monitoring was the entry into force since 01.01.2026 (Article 24.5 of the Federal Law No. 89-FZ dated June 24, 1998 “On Environmental Fee”) of the obligation for importers to ensure the recycling of waste from the use of goods:

• for imports from EAEU countries – from the day the goods are recognized
• for imports from countries outside the EAEU – before the day of release by the customs authority for domestic consumption.

Good news: on December 31, 2025 the Federal Law No. 495-FZ dated December 28, 2025 “On Amending Article 29¹ of the Federal Law “On Production and Consumption Waste” and Certain Legislative Acts of the Russian Federation” came into force. This law postponed the enactment of the new rules until 01.01.2028.

More details of the changes

The adopted law alters the timeline for the environmental fee reform and implemented a key proposal from the draft law by the Russian Ministry of Natural Resources published on 20.10.2025 (which we covered in our previous overview): the transitional provisions for importers from countries outside the EAEU have been extended by two years – until January 1, 2028 (instead of the originally set date of January 1, 2026).

Therefore, this year the submission of reports and payment of the environmental fee should be carried out according to the usual terms.

However, the adopted law did not implement all proposals included in earlier versions of the draft.

In this regard, we recommend continuing to monitor potential changes amidst the ongoing discussions between the regulator, business and relevant ministries.

What needs to be done in any case? Reporting and terms for the environmental fee payment for 2025.

The Federal Service for Supervision of Natural Resources (Rosprirodnadzor) has reminded of the terms for submitting environmental fee reports and making payments for 2025.

By April 15, 2026 manufacturers and importers of goods and packaging subject to recycling are to submit their environmental fee reports to Rosprirodnadzor and pay the environmental fee for 2025.

We would like to remind you that the List of goods and packaging, the waste from which is subject to recycling, was approved by the Russian Government Decree No. 2414 dated December 29, 2023.

Furthermore, it is important to note that the environmental fee is not included in the Unified Tax Payment (UTP) and must be paid separately.

List of required reports:

• Report on the weight of goods and packaging (form of the Appendix 1 to the Rules approved by the Russian Government Decree No. 741 dated May 31, 2024).
• Report on self-executed recycling (form of the Appendix 1 to the Rules approved by the Russian Government Decree No. 742 dated May 31, 2024). This report is submitted only if the company performs the recycling itself.
• Calculation of the environmental fee amount (form of the Appendix 1 to the Rules approved by the Russian Government Decree No. 1990 dated December 30, 2024).

All listed forms are to be submitted in electronic form. The authority recommends using the personal account of natural resource user for this purpose.

We will be glad to answer your questions.

Dear colleagues,

Please accept our sincere congratulations on the upcoming New Year and Christmas! 

May the coming year bring new achievements, harmony and professional success!

We wish you and your loved ones happiness, health and prosperity!

Thank you for your trust, support, and productive cooperation!

With best wishes,

Your swilar team

Dear colleagues,

In response to numerous inquiries from companies about the environmental fee and the active changes in this area expected in 2025-2026, we have prepared an overview of the topic to help you understand some key aspects.

The environmental fee and related reporting represent a system that reflects the responsibility placed on manufacturers and importers to consider the fate of their goods and packaging after they have served their term. The system is becoming more complex, the rates are increasing and control is tightening. We examine the upcoming changes and their implications for companies.

Who is liable?

The following entities are required to pay the environmental fee and submit reporting:

• Manufacturers of goods and packaging released within the territory of the Russian Federation.
• Importers bringing goods and packaging from abroad.
• Disposal companies, if they take on the responsibility of meeting disposal standards.

Important: the obligation arises for the entity that first releases the goods or packaging on the market in the Russian Federation, provided that the goods or packaging are included in the relevant List. The environmental fee is calculated considering the standards.

What changes take effect in 2025

1. Significant rate increase

The Government has approved new base rates for the environmental fee for 2025–2027 (Resolutio No. 1041 dated August 1, 2024). Compared to 2024, the rates will increase by 15% in 2025, with further planned increases in subsequent years.

• Example for tires and rubber:
  • 2025 — 10,310 RUB/tonne
  • 2026 — 11,135 RUB/tonne
  • 2027 — 11,580 RUB/tonne

• Example for textile products:
  • 2025 — 18,750 RUB/tonne
  • 2026 — 20,250 RUB/tonne
  • 2027 — 21,060 RUB/tonne

Furthermore, the Ministry of Natural Resources has already prepared a new draft resolution that starting from 2026 could introduce even higher rates (e.g., for textiles — up to 89,184 RUB/tonne). This indicates a sustained trend of increasing environmental compliance costs.

How to calculate? In its inquiries the Federal Service for Supervision of Natural Resources refers to data from customs declarations. These declarations contain information about the goods, including weight, codes and volumes. All this data is automatically compared.

Data required for calculating the environmental fee:

1. Manufacturers of goods – a list of goods indicating the code in accordance with the Russian Classification of Products by Economic Activities (OKPD2), product name, the weight of all manufactured products.
2. Importers – the customs declaration which specifies the HS code of the imported goods, the packaging code in most cases and the gross and net weights.

2. Tightening of the rules for importers from 2026.

From 1 September 2024 to 31 December 2025 a special experimental regime will apply to certain types of goods: reporting and payment of environmental fee should be completed before the date of their release by the customs authorities for domestic consumption. 

The current version of the law stipulates that upon completion of the experiment (from 01.01.2026), these rules will become mandatory for all importers (the Article 24.5. Environmental Fee of the Federal Law No. 89-FZ dated 24.06.1998).

The obligation to ensure the recycling of waste from the use of goods will arise for the importer of goods:

1. for imports from EAEU countries – from the day the goods are recognized.
2. for imports from countries outside the EAEU – before the day of release by the customs authority for domestic consumption!

An alternative may be to submit a notification of intent to dispose of the waste independently or to provide a bank guarantee or surety agreement from the disposal company for the amount of the fee (the term of the guarantee or surety agreement shall not be earlier than 15 October of the following year).

The good news is that legislators are considering extending the experimental regime – see the draft of the Federal Law (prepared by the Russian Ministry of Natural Resources). The ministry has proposed extending the experiment on the payment of environmental fees prior to the submission of customs declarations for another year, as well as easing the conditions for paying the fees prior to the submission of declarations (within 90 days after the release of goods). 

The bill was submitted on 20 October 2025 – we recommend monitoring the progress of this initiative.

Liability: risks and fines

The risks should not be underestimated. The Federal Service for Supervision of Natural Resources actively employs a system of cross-checks, comparing data from companies’ reports with information from customs declarations and other state databases.

The fines for violations are substantial:

• For failure to submit or late submission of reports: for legal entities — from 70,000 to 150,000 RUB.
• For inaccurate data in reports: the fine for legal entities is twice the amount of the fee (but not less than 250,000 RUB).
• For missing payment deadlines or non-payment of the fee: the fine for legal entities is three times the unpaid amount (not less than 500,000 RUB).

Who is exempt from payment?

Payment is not required, but reporting is still mandatory if:

• The goods are for export.
• They are used as raw materials or components for manufacturing other goods.
• The recycling target has already been met (independently or through an accredited recycling operator).

Manufacturers and importers who recycle their products are subject to special statistical waste management reporting. This is the annual form 2-TP (waste).

Practical recommendations for business

1. Audit. Verify whether your goods and packaging are included in the current list (Government Resolution No. 2414 dated December 29, 2023).
2. Be proactive. If you receive a letter from The Federal Service for Supervision of Natural Resources, it is advisable to comply with the requirement within the specified deadline (submit the report, pay the fee) and only then challenge their position. A delay results in an automatic fine.
3. Remember the deadlines for 2025:
   • Submit reports — by April 1, 2026.
   • Pay the environmental fee — by April 15, 2026.

Important: If April 15 falls on a weekend or holiday, the fee should be paid before this date. The deadline is not extended to the next business day.

Conclusio

The environmental fee is no longer a formality but have become a significant expense and a serious regulatory risk for businesses. Rising rates and tighter controls signal that it is time to build a transparent system of environmental reporting and waste disposal. Those who do so now will not only avoid multimillion fines, but also lay the foundation for sustainable development in the new economic reality.