Implementation of new EPR Rules for importers delayed until 2028

On 31 December 2025, a Federal Law* came into force, which postponed the introduction of key new requirements for importers of goods from non-EAEU countries until 1 January 2028. These requirements pertain to new rules under the Extended Producer Responsibility (EPR) framework, namely:

• Advance payment of the environmental fee (prior to customs clearance); and
• Submission of a report on the weight of imported goods separately for each consignment.

Consequently, the term of the experiment to test the new mechanism for specific categories of imported goods has also been extended until this date.

It is important to note that the rules for conducting the experiment during its extended period have not yet been established. Therefore, importers of goods covered by the experiment currently pay the environmental fee and submit reports according to the general procedure - by 15 April of the year following the reporting period.

New rules for conducting the experiment are to be adopted within 2026.

These rules may include the following changes:

• Revision of the list of goods subject to the experiment;
• Introduction of a deferral of up to 90 calendar days from the date of import for payment of the environmental fee and submission of the report on the weight of imported goods; and
• Removal of the suretyship agreement from the list of available methods for securing the environmental fee payment in case of failure to independently fulfil waste disposal obligations.

We recommend that all importers closely monitor the development and approval status of the new experimental rules. This will allow them to prepare in advance to comply with the established requirements should the goods they import fall under these rules.

* In Russian