Russian plastics processors are once again trying to adjust the requirements for ecocharges for packaging under Extended Producer Responsibility (EPR). The companies point to the unreasonableness of using increasing coefficients that would raise environmental charges several times over, as well as the impossibility of enforcing the methodology for their calculation. However, the regulators do not see the need to adjust the principles of environmental fees, according to the Kommersant newspaper.
In July, the Union of Plastics Processors (SPP) sent comments to the Russian Environmental Operator (REO, Ministry of Natural Resources) and to the Government Office on the parameters of the legislation on the ROP.
The updated ROP mechanism, which comes into effect in 2024, envisages a gradual increase in the mandatory packaging recycling norm for manufacturers and importers from 55% in 2025 to 100% by 2027. Companies failing to meet the standard must pay an environmental levy.
Criticism of the calculation of environmental payments
The SPP letter notes that now the prime rate for all polymer groups is proposed at the level of 12.38 thousand rubles per ton, which takes into account all the costs associated with waste treatment and should cover the costs associated with disposal. But, the SPP adds, it is planned to introduce increasing coefficients that will increase the rates by 2-5 times, which will raise the cost of some materials against others.
According to the calculations of one of the industry participants, taking into account the coefficient, the ecollection rate for transparent PET (polyethylene terephthalate) will be 5.7 times higher than the rate for paper packaging, and the rate for a product made of polypropylene — 11.5 times.
The SPP asks to specify the cost of utilization of paper and cardboard, as well as packaging made of these materials, which is now equal to zero, in the sums of calculations of the basic rates of the eco-collection. The SPP warns that the increase in the price of polymer packaging will not reduce the demand for it, but will cause an increase in the prices of packaged goods.
Peter Bazunov, General Director of SPP, points out that in Italy, for example, there are different eco-payment rates for different types of polymer packaging, which encourages consumers to choose the most recyclable types of packaging.
Petr Bobrovsky, Executive Director of the Association of Manufacturers of Perfumes, Cosmetics, Household Chemicals and Hygiene Products, adds that the methodology for calculating the ecolarge rates contains parameters that are legally impossible to determine, such as “recoverability,” “recyclability,” and “need for recyclable materials.” These factors influencing the calculation of the payment are proposed to be determined on the basis of a survey, the procedure for which is absent, he points out.
General Director of “Georg Polymer” Luchesa Nabatova notes that the main problem with the methodology of calculating the ecolarge is the incommensurability of payments with the economics of packaging manufacturers. In 2027, if the methodology is maintained, the company will have to pay only 495.5 million rubles for utilization, which is 2.3 times more than the amount of all taxes and fees in 2023, she points out.
The Ministry of Natural Resources emphasized to Kommersant that the eco-collection rates are set in accordance with the law, and the funds are used to create infrastructure for waste management. Statements about the growth of prices for products, the ministry assured, are not confirmed. According to the calculations of PPK REO, the cost of packaged products will rise by a maximum of 1% for certain types of products.
Mr. Denis Butsaev, General Director of PPC REO, said that the comments of business were considered during the adoption of by-laws and the law on the reform of ROP and there can be no disputes regarding the methodology for calculating the prime rates of eco-collection, as the methodology has been approved by the government.
As Mr. Butsaev notes, it is now important to adopt reasonable values of the prime rates of ecollection, corresponding to the costs of waste management. He added that the draft decree with the values of the prime rates of the eco-collection has been submitted to the government.