Doing Business in Russia

40 Doing Business in Russia Despite the fact that the Recycling Law is already in force and the obligation to submit reports is effective from 1 April 2016, the legislative act has not been finalised yet and requires a number of explanations and clarifications. Based on this in 2016, producers and importers bear no responsibility for failures to submit reports. Consequences exist for 2017 and thereafter. These primarily relate to the challenges companies face when preparing their regular accounts. Among other things, an amendment has introduced a requirement to specify the name and amount of goods and packaging used when importing goods or introducing them to the market with an accuracy of one kilogram. In most cases, neither customs declarations nor accounting reports provide this kind of information. In addition to this, there are other significant issues that have still not been resolved by legislators. Despite the fact that no penalties have been stipulated for failures to comply with waste disposal requirements in 2016, the current year will still be important for both producers and importers. If the lack of reports or incorrect data entail no liabilities this year, this will fundamentally change in 2017 and thereafter. Most companies are wrong in believing that they fall within the scope of the Recycling Law by identifying waste disposal as the traditional destruction of products, and, due to their goods being absent from the List, disregarding the packaging in which the goods are imported or introduced to the market. In our opinion, producers and importers should check to see if their products and packaging are on the List, as well as analyse how many of their products and imports already fall under its scope. If they understand that their products and packaging come under the List's scope, they should not only develop and set up inventory accounting procedures, but also choose the most convenient and beneficial option for them: whether to take responsibility for the entire recycling procedure, establish associations (unions) for professional disposal, or pay the environmental duty. KPMG © 2016 KPMG. All rights reserved. Novosibirsk

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