A draft resolution of the Government of the Russian Federation titled “On Amending Certain Acts of the Government of the Russian Federation” (Draft ID 02/07/03-26/00165928) has been published on the Federal Portal for Draft Regulatory Acts. The amendments are intended to resolve current inconsistencies related to the ongoing pilot program on environmental fee.

As a reminder, an experiment was conducted in 2024-2025 regarding certain types of goods and packaging imported from countries outside the Eurasian Economic Union (EAEU), involving separate rules for paying the environmental fee and submitting reports. We discussed this in our webinars.

It was originally assumed that the pilot program would end on January 1, 2026, and its rules would apply to all types of goods and packaging imported from countries outside the EAEU. However, by Decree of the Government of the Russian Federation No. 2228 dated December 30, 2025, the pilot program was extended until December 31, 2027.

At the same time, the deadlines for importers to submit reports under the pilot program regarding goods and packaging imported into the Russian Federation between January 1, 2026, and December 31, 2027, from non-EAEU member states have not yet been approved, as the original rules of the pilot program established deadlines for 2024-2025 only.

As a result, importers participating in the pilot program lack a clear understanding of the format and deadlines for submitting reports. At the same time, pursuant to paragraph 1 of Article 24.2 of Law No. 89-FZ, importers remain obligated to ensure the disposal of waste generated from the use of goods. At present, it is not possible to fulfill this obligation.

The draft resolution proposes establishing the following deadlines for submitting reports and paying the environmental fee:

– for goods / package imported to Russia from September 1, 2026, to September 1, 2027 – by the date of their release by the customs authority for domestic consumption;
– for goods / package imported to Russia from January 1 to August 31, 2026 (for 2026), from September 1 to December 31, 2027 (for 2027) – by April 15 following the reporting period (by April 15, 2027, and by April 15, 2028, respectively).

We are monitoring developments on this topic and will report on them in our news updates and webinars.