What environmental reporting should a small and medium-sized business submit: a cheat sheet for an accountant

1. Waste reporting for SMEs
2. Technical report on waste management
3. Form 2-TP (air)
4. Form 4 – OS (current costs)
5. Form 2-TP (waste)
6. Declaration of payment for negative environmental impact
7. Report on the PEC program

We lived for a whole year under the new system of environmental control and supervision.
Now enterprises already know which hazard category the objects of negative impact they own belong to and what documents must be developed. Many have already carried out industrial environmental control during the year according to the new rules. At the end of December, the country's first comprehensive environmental permit for a category I facility was solemnly issued. In 2021, enterprises reported under the new rules for the first time. Here is material about how the environmental reporting campaign 2021 took place. You can find the latest material for 2021 by clicking the button below!

Environmental reporting 2021

Waste reporting for SMEs in 2020

9 years have already passed since this reporting was introduced for small and medium-sized businesses. It was submitted annually by January 15 and was called “Report on the generation, use, disposal and disposal of waste by small and medium-sized businesses.” The procedure and form for submitting a report for SMEs operating NDC facilities related to the federal level of environmental supervision in accordance with Resolution No. 903 of 08/28/15 was regulated by Order of the Ministry of Natural Resources of the Russian Federation dated 02/16/2010 N 30. For facilities at the regional level of supervision, forms and the order was established by local authorities. After the changes came into force last year, it was not clear whether it was necessary to submit these reports for 2021. Let’s look at the requirements of the law:

Federal Law dated June 24, 1998 N 89-FZ (as amended on August 2, 2019) “On production and consumption waste”

Article 18. Standardization in the field of waste management

[…]

3. For legal entities or individual entrepreneurs carrying out economic and (or) other activities at category I facilities, determined in accordance with legislation in the field of environmental protection, waste generation standards and limits on their disposal are established on the basis of a comprehensive environmental permit provided for by law in the field of environmental protection.

4. Legal entities and individual entrepreneurs carrying out economic and (or) other activities at objects of category II, defined in accordance with legislation in the field of environmental protection, include information on the volume or mass of waste generated and disposed of in the environmental impact declaration in accordance with environmental legislation.

5. Legal entities and individual entrepreneurs carrying out economic and (or) other activities at objects of category III, determined in accordance with legislation in the field of environmental protection, submit to the federal executive body authorized by the Government of the Russian Federation or the executive bodies of state power of the constituent entities of the Russian Federation in accordance with their competence, in a notification procedure, reporting on the generation, use, neutralization, and disposal of waste.

6. When carrying out economic and (or) other activities at objects of IV category, determined in accordance with legislation in the field of environmental protection, the development of waste generation standards and limits on their disposal and reporting on the generation, use, neutralization, and disposal of waste is not required.

[…]

These provisions came into force on January 1, 2021. Before this period, Article 18 stated that small and medium-sized businesses that generate waste must submit reports on the generation, disposal, neutralization and disposal of waste. Last year, the majority of SMEs submitted these reports. At the same time, the reporting form that enterprises operating category III facilities must submit, and which is specified in the law, was not established during 2019. In addition, according to the provisions of Federal Law No. 219-FZ, enterprises operating category III facilities will have to submit similar reports in the area of ​​impact on atmospheric air, the form of which has also not been established today.

At the end of 2021, several enterprises sought clarification from authorized authorities regarding the need to submit reports for SMEs. The answers, as always, are vague. One of the responses to a request to the Ministry of Natural Resources of the Moscow Region nevertheless explained that the division into SMEs when considering waste management issues is no longer used; only the division depending on the category of NDC objects is applicable. In accordance with this, reporting of this kind should only be provided by enterprises operating category III NVD facilities. Thus, all other categories are exempt from this reporting, and for category III its form is not established. Most likely, reports will be accepted in the forms and in the order in which SME reports were accepted.

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Cost of services

Find out the cost of reporting for your company Please note that the cost of services for each client is calculated individually. To calculate the exact cost, we send the client a questionnaire, based on which we can issue the most reliable commercial offer. Tariffs can be combined and complement each other.

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Technical report on waste management in 2021

Until January 1, 2021, it was mandatory for large business enterprises with PNOOLR to pass it. The NOLR project operated for 5 years, subject to annual submission of a report . For facilities with a federal level of supervision, the project and technical report were developed in accordance with Order of the Ministry of Natural Resources of Russia dated 05.08.2014 N 349 “On approval of Guidelines for the development of draft standards for waste generation and limits on their disposal”, for “regionals” - in accordance with regional guidelines and procedures in force in accordance with the established procedure. In case of untimely submission of a technical report to the authorized body, the enterprise faced punishment under Article 8.2 of the Code of Administrative Offenses of the Russian Federation. Once 2019 arrived, conditions changed. Thus, standards and limits for the generation and disposal of waste are now only received by enterprises that have category I facilities as part of obtaining a comprehensive environmental permit

Permits for the emission of pollutants into the atmospheric air, limits for emissions of pollutants, discharge permits, discharge limits, standards for waste generation and limits for their disposal, obtained by legal entities and individual entrepreneurs carrying out economic and (or) other activities at NDC facilities, related to objects of categories I and II, until January 1, 2021, are valid until the day of expiration of such permits and documents or until the day of receipt of the IEP or submission of a DOVOS during the validity period of such permits and documents (in accordance with the Federal Law of December 25, 2018 N 496-FZ). From January 1, 2021 until the receipt of the IER, it is possible to issue or re-issue permits and documents that will be valid until the day the IER is received. For objects of category II, it is necessary to submit a DEVOS no later than the day of expiration of at least one of the specified permits and documents. In mid-2021, new changes were made (Federal Law dated July 26, 2019 N 195-FZ), according to which legal entities and individual entrepreneurs operating at category I facilities included in the list of 300 pilot facilities are required to apply for an IEP in period from January 1, 2019 to December 31, 2022 inclusive. Facilities not included in this list must submit an application and receive an IEP before January 1, 2025. Before this period, in accordance with the still valid PNOOLR for these objects, it is necessary to submit technical reports according to established procedures.

If an object belongs to category III, it needs to submit a report on the generation, use, neutralization, and disposal of waste. Since the report form has not yet been adopted, the question remains open. At the same time, the order of the Ministry of Natural Resources of Russia dated February 25, 2010 No. 50 “On the Procedure for the development and approval of waste generation standards and limits on their disposal” for NDC facilities at the federal level of supervision is still in force, as well as local regulations for regional facilities, and, if necessary, or if you wish, a technical report can be submitted “just in case”. In the practice of the author of the article in 2021, such reports were accepted, since the authorized body could not refuse to accept it.

If the NDC object belongs to category IV, the PNOLR is no longer valid for it; accordingly, a technical report does not need to be submitted as part of environmental reporting 2021.

Form 2-TP (air) as part of environmental reporting 2021

Statistical reporting on atmospheric air protection - form 2-TP (air) is submitted to Rosprirodnadzor before January 22 of the year following the reporting year. Order of Rosstat dated November 8, 2018 N 661 “On approval of statistical tools for the organization of federal statistical monitoring of atmospheric air protection by the Federal Service for Supervision of Natural Resources” approved a new form of this reporting. Persons required to submit reports are persons with stationary emission sources whose volumes of permitted emissions of pollutants under the NDC exceed 10 tons per year or 5 to 10 tons per year inclusive if the emissions contain substances of hazard class 1 and (or) 2. If the NVGs operated by a legal entity or individual entrepreneur are located on the territory of different constituent entities of the Russian Federation, then the report in the form is provided separately for each subject. This year there have been no changes in the procedure for filing these reports.

Responsibility for failure to comply with legislation

Administrative liability awaits every entrepreneur who fails to submit reports on time or fail to pay payments. Responsibility is assigned in the form of fines.

For example, for improper use of waste, an official faces a fine of up to 30,000 rubles, and a legal entity of up to 250,000 rubles.

Also, entrepreneurs conducting their activities officially may have their rights to engage in their activities restricted for varying periods of time. If reporting is not submitted on time, then officials will receive a fine of 2,000 rubles, and legal entities - 10,000 rubles.

It is very important to understand that reporting forms, deadlines and responsibilities may change. All changes and amendments are made to the relevant laws and posted on all information resources.

Entrepreneurs who are interested in this type of activity are required to promptly view the news and familiarize themselves with all changes.

In this case, the responsibility lies solely with them. All amendments of this kind can be obtained on the official website.

The activities of Rosprirodnadzor are very important for the state and for the planet as a whole.

It is thanks to this body that control over the reasonable use of natural resources occurs.

However, entrepreneurs need to understand that it is important not only to fill out reports efficiently and submit them on time, but most importantly - to take care of the world around them, and not about their own profit, to effectively carry out their activities and save natural resources, since many of them can no longer be replenished .

Form 4 – OS (current costs) 2020 model

A new order was issued in 2021 based on the form of this reporting. Order of Rosstat dated July 18, 2019 N 412 (as amended on October 17, 2019) “On approval of federal statistical observation forms for organizing federal statistical observation of agriculture and the natural environment.” Federal statistical observation form N 4-OS “Information on current costs of environmental protection” is provided by legal entities and individual entrepreneurs who have fixed assets for environmental protection purposes, carry out environmental protection measures, and have facilities that have a negative impact on the environment.

Information is provided if there are current costs for environmental protection and (or) payment for environmental services in excess of 100 thousand rubles per year. Reports are still submitted to Rosstat until January 25 of the year following the reporting year.

Form 2-TP (waste) sample 2020

One of the most stable types of reporting as a subject of environmental reporting 2021 this year also did not escape changes. Moreover, the form of the order changed twice in a year. That is, the first changes occurred with the release of the order by Rosstat Order No. 459 dated August 19, 2019, and 4 months later the new Rosstat Order No. 766 dated December 12, 2019. Thus, according to Order No. 459, not even one report, which clearly shows us the pace of change in environmental legislation.

The new form 2-TP (waste) comes into force from the 2019 report. It must be provided by the following persons:

• business entities operating in the field of industrial and consumer waste management;
• regional operators for the management of municipal solid waste (hereinafter referred to as MSW);
• MSW management operators.

Let us recall that previously this form was submitted by a wider range of people (comparison of three regulations regarding requirements for the range of persons):

Thus, economic entities related to SMEs should not submit Form 2-TP (waste), provided that three conditions are simultaneously met for them:

• only MSW weighing less than 0.1 tons is generated;
• an agreement has been concluded with a regional operator for the management of MSW;
• There are no activities for processing, recycling, neutralization, or disposal of waste.

Form 2-TP (waste) must be submitted to the Rosprirodnadzor TO by February 1. In general, the differences in the new order are insignificant; for example, more detailed explanations have been given on the issue of who should fill out this or that section of the form and in what cases, and the form of some sections has changed.

Reporting of individual entrepreneurs without employees

The legislator was quite loyal to this category of taxpayers, reducing mandatory reports to a minimum. Individual entrepreneurs are allowed not to keep accounting records, subject to accounting for income, or income and expenses, or other objects of taxation and physical indicators (subclause 1, clause 2, article 6 of Law No. 402-FZ).

As for reporting on taxes and fees, an individual entrepreneur without employees at the end of the calendar year (tax period) submits:

• on the general system - a VAT return and a personal income tax return;
• on the simplified tax system - a declaration for the single tax of the simplified tax system;
• for UTII - a declaration for a single tax on imputed income for certain types of activities.

No more reports needed!

Declaration on fees for negative environmental impact in 2021

As part of environmental reporting 2021, this declaration, the procedure for its submission and form have not changed. According to the law, the following categories of persons are required to file a declaration and pay a fee:

Federal Law of January 10, 2002 N 7-FZ) “On Environmental Protection”

Article 16.1. Persons obligated to pay fees for negative environmental impact

1. Payments for negative impacts on the environment are required to be made by legal entities and individual entrepreneurs carrying out economic and (or) other activities that have a negative impact on the environment on the territory of the Russian Federation, the continental shelf of the Russian Federation and in the exclusive economic zone of the Russian Federation (hereinafter referred to as - persons obligated to pay a fee), with the exception of legal entities and individual entrepreneurs carrying out economic and (or) other activities exclusively at objects of category IV.

Payers of fees for the negative impact on the environment when disposing of waste, with the exception of solid municipal waste, are legal entities and individual entrepreneurs whose economic and (or) other activities generated waste. Payers of fees for the negative impact on the environment when disposing of municipal solid waste are regional operators for the management of municipal solid waste, operators for the management of municipal solid waste, carrying out activities for their disposal.

The deadline for filing the declaration is March 10, the deadline for paying the fee is until March 1.

According to clause 1 of Article 4.2 of Federal Law No. 7-FZ, legal entities and individual entrepreneurs who operate at Category IV facilities (in accordance with the criteria of Decree of the Government of the Russian Federation No. 1029 dated September 28, 2015) do not need to pay a fee for the NVOS. Those users of natural resources whose objects do not have a category currently have to pay a fee, since clarifications to the Criteria for determining the category of an object have not yet been made, and many objects find themselves in a legal vacuum.

Regional operators pay for the disposal of MSW at landfills. By January 1, 2021, all constituent entities of the Russian Federation were required to switch to a new MSW management system in accordance with regional programs in the field of waste management and territorial waste management schemes, as well as select a regional operator. According to the law, when placing production and consumption waste at waste disposal sites that exclude a negative impact on the environment and are determined in accordance with the legislation of the Russian Federation in the field of waste management, no fee is charged for the placement of production and consumption waste.

From January 1, 2021, when calculating the fee, the provision of Part 5 of Article 16.3 on additional coefficients comes into force:

That is, for objects of categories I and II from 2021, for violation of the standards of NDV, VSV, VAT, VSS, the fee will be charged 25 times and 100 times. Category II facilities that have submitted an EIA pay for the volumes and masses of emissions and discharges indicated therein. If they are exceeded compared to those specified in the DOIA, you will have to pay 25-fold and 100-fold. For objects of category III, the fee for the NVOS will be charged without increasing factors in case of timely submission of the above-mentioned reports on waste generation.

Among the new products this year in the field of paying fees, we can note the emergence of the long-awaited procedure for offset and return of amounts of overpaid (collected) fees, approved by Order of Rosprirodnadzor dated June 20, 2019 N 334″. According to this order, the offset of the amounts of overpaid (collected) fees is carried out according to those types of negative impact on the environment (budget classification codes), as well as according to the OKTMO codes by which the fee was calculated and paid. The offset is carried out by Rosprirodnadzor at the location of the NDC facilities upon application no later than 3 months from the date of receipt of the application. In this case, you first need to sign a reconciliation report with Rosprirodnadzor without disagreement.

More information about the NVOS

Environmental fee

Who is obligated to pay and report?

In general, companies and entrepreneurs that in the reporting year produced or imported goods that are subject to mandatory disposal after loss of consumer properties must pay an environmental fee and submit reports. The list of such goods (including packaging) was approved by Decree of the Government of the Russian Federation dated December 31, 2020 No. 3721-r.

ATTENTION. When preparing reports for 2020, you must be guided by the list approved by Decree of the Government of the Russian Federation dated December 28, 2017 No. 2970-r - despite the fact that in 2021 this document is no longer valid.

There are three options.

1. The organization or individual entrepreneur does not produce or import goods and packaging from the specified list. Then you don’t need to pay the environmental fee and report on it.
2. An organization or individual entrepreneur is a manufacturer or importer of goods from the list. In this case, it is necessary to calculate the amount of the fee and submit reports. But you don’t always have to pay the environmental fee, but only if the recycling standards established for the reporting year are not met.
3. An organization or individual entrepreneur produces or imports packaging from the list. The eco-fee for the packaging of goods is paid by the manufacturers of these goods if they sell it to the end consumer. The environmental fee for reusable packaging is paid by its manufacturer (for more details, see: “Environmental fee for 2021: how to prepare a report and calculate the amount of the fee”).

The amount of the environmental fee for the reporting year is the product of three quantities: the mass of the product and (or) packaging, the corresponding recycling standard and the fee rate. An example of a calculation is given in the article “Environmental fee: who, how much, when and how should pay for 2021.”

Environmental fee payment deadline

Until April 15 of the year following the reporting year. This date is included in the deadline (letter of the Ministry of Natural Resources dated 04/04/19 No. 01-19-44/7874). Accordingly, the deadline for paying the environmental fee for 2021 is April 15, 2021.

Automatically generate a payment invoice for payment of the environmental fee based on the data from the declaration and submit all collection reports Submit an application

Reporting under the PEC program in 2021

Reporting under the industrial environmental control program is an annual report on the implementation of the IEC program for objects of categories I-III. The PEC program includes control over emissions into the atmosphere, discharges into water bodies, and waste management activities. Order of the Russian Ministry of Natural Resources dated June 14, 2018 N 261 approved the reporting form for PEC. Reporting on PEC activities carried out must be submitted by March 25, 2021.

In October 2021, methodological recommendations for filling out a report on the PEC program appeared, contained in Order No. 522 dated October 16, 2021; in accordance with the letter of the Ministry of Justice of Russia dated December 29, 2021 No. 01/171702-102, they did not require state registration. In November 2021, the recommendations were published on the official online legal information portal. They can help you understand how to complete report tables to meet the 2021 environmental reporting standards.

More about PEC