2-TP Waste - until February 1, 2021.
The environmental report is submitted to legal entities. persons and individual entrepreneurs to the territorial department of Rosprirodnadzor.
The reporting includes information on the generation of waste (MSW and industrial waste), its processing, disposal, transportation and disposal. Declaration of goods sold in the Russian Federation subject to subsequent disposal - until April 1, 2021.
The declaration is submitted to Rosprirodnadzor at the place of registration of the manufacturer or supply of imported products. The declaration procedure is established by Government Decree No. 1417 of December 24, 2015.
The basis for including goods in the declaration is primary accounting or customs documentation.
Report on compliance with waste disposal standards from product use - until April 1, 2021.
The form must be filled out and submitted to Rosprirodnadzor by product manufacturers and importers. It is necessary to report for products that are included in the federal list of goods that must be disposed of after use/use. Information about the product and its packaging is provided on separate sheets. The reporting reflects the name of the product, its code, name and code in the EAEU HS, weight (kg), quantity, details of documents confirming the fact of disposal, quantity of waste, including for which an environmental fee will need to be paid.
Report on available technological units for waste disposal - until April 1, 2021.
The procedure is regulated by Government Decree No. 1520 of December 30, 2015. Legal entities are required to provide information to Rosprirodnadzor. persons and individual entrepreneurs working in the field of waste management from the use of goods.
Want to know what safety legislation changes have occurred in 2021? Come to our online conference! Participation is free.
Report on places for collecting waste generated from the use of finished products - until April 1, 2021.
For rent provided that these places are organized by a legal entity. persons and individual entrepreneurs licensed to work on waste management from the use of goods.
PEC report - requirements
Production control in the field of environmental protection is an important element of the environmental protection activities of an enterprise. Implementation of industrial environmental control is a set of measures taken by an enterprise to ensure the implementation of measures related to environmental protection in order to comply with environmental requirements.
Requirements for the implementation of industrial environmental control apply only to enterprises that are objects of negative environmental impact (NVOS) of categories 1, 2, 3.
Enterprises carrying out their economic and (or) other activities on ENVOS categories 1, 2, 3 are required to:
- develop and approve a program for industrial environmental control (clause 2 of Article 67 of the Federal Law of January 10, 2002 No. 7-FZ “On Environmental Protection”,
- carry out industrial environmental control, namely: appoint persons responsible for carrying out industrial environmental control, carry out control over emissions into the atmospheric air, keep records of generated, disposed, neutralized, transferred to other persons or received from other persons, as well as disposed waste ,
- carry out documentation of information and storage of data obtained from the results of industrial environmental control,
- provide reporting on the organization and results of the implementation of the industrial environmental report.
A nuance regarding boiler houses operating on primary and reserve fuels:
As follows from the appeal, the operation of boiler houses implies two technological modes - operation on the main type of fuel and operation on the reserve type of fuel. Taking into account the above, in the opinion of the Russian Ministry of Natural Resources, the Schedule for monitoring stationary sources of emissions (hereinafter referred to as the Schedule) is included in the PEC program ) must be drawn up taking into account the specified features based on paragraph 1 of the Requirements. In the event that emissions from boiler houses when operating on reserve fuel are not taken into account in the report on the organization and on the results of implementing the IEC (hereinafter referred to as the Report), in the opinion of the Russian Ministry of Natural Resources, emissions data boiler rooms may be underestimated.
letter of the Ministry of Natural Resources dated November 7, 2021 No. 12-44/27613
Payment of the environmental fee and submission of a calculation of its amount is due by April 15, 2021.
The rules for collecting, paying, and returning environmental fees are established by Decree of the Government of Russia dated October 8, 2015 No. 1073. The obligation to pay it, as well as submit reports, is imposed on manufacturers and importers of products that need to be disposed of after use. This list was approved at the legislative level by Government Order No. 2970-r dated December 28, 2017. The form for calculating the amount is determined in the order of Rosprirodnadzor dated August 22, 2021 No. 488.
PEC report form with comments
You can download the new report form here:
You can submit the PEC report through your personal account as a natural resource user.
If there is no information about the best available technology (BAT) used, then dashes are added in Table 1.2 . According to Table 1.3, to conduct production control at sources of emissions of harmful pollutants and discharges of harmful substances, enterprises either have their own laboratory or hire a third party. It doesn’t matter - it is important that the laboratory is accredited!
Table 2.1. is filled out according to the control schedule for sources of pollutant emissions, which is mandatory in the enterprise’s draft MPE.
Columns 2-7 of table. 2.2. are filled in according to the draft MPE data. Columns 8, 10 are filled out based on the production control protocols at the enterprise sources. See the frequency of monitoring in the schedule; if quarterly measurements are recorded for a specific source and pollutant, then accordingly there should be 4 entries in one line. Column 11 - I hope it is clear that such cases simply should not happen. Otherwise, you may be forced to review the approved MPE standards and be punished for exceeding them, accordingly.
The actual emission is calculated using the formula:
G=V*C/1000, g/s where: V is the volume of exhaust gases, cubic m/s, C is the concentration of dust supplied for cleaning, mg/cub.m.
By filling out table 2.2. A comment appeared in the letter of the Ministry of Natural Resources dated November 7, 2021: 12-44/27613, the letter is posted at the end of this article:
With regard to pollutants, the frequency of monitoring of which is set less than once a year, we believe it is possible to use the data obtained during the IPC for the purpose of annual submission of the Report, and also take it into account when calculating the payment base for calculating fees for negative environmental impacts.
At the same time, we recommend that in column 10 of Table 2.2 of the Report form “Results of monitoring stationary sources of emissions of pollutants into the atmosphere”, indicate the date of sampling, and in column 12 provide explanations regarding the frequency of monitoring for this substance established by the Schedule.
That is, the sampling date is obtained - once every 5 years, sampling was carried out in 2021 - table 2.2. must be filled out according to 2018 data (the selection date is set to ****2018).
Table 2.3. is filled out according to the sanitary protection zone control schedule; if the enterprise is located sufficiently far from the residential sector, this schedule will not be included in the draft MPE.
Similar to filling out Table 2.2.
By order of the Ministry of Natural Resources of the Russian Federation dated June 23, 2020 No. 383, tables 2.5, 2.6 were added to the PEC report, table 3.1 was changed:
Table 2.5. Information on approved emission quotas, on the compliance of emissions at quota facilities with such quotas, if the facility is included in the list of quota facilities in accordance with paragraph 5 of Article 5 of the Federal Law of July 26, 2019 N 195-FZ “On conducting an experiment on quotas for emissions of pollutants and introducing amendments to certain legislative acts of the Russian Federation in terms of reducing air pollution” and establishing emission quotas for such an object in accordance with paragraph 7 of Article 5 of Law No. 195-FZ
Table 2.6. Information on the implementation of action plans to achieve emission quotas, if the facility is included in the list of quota facilities in accordance with paragraph 5 of Article 5 of Law N 195-FZ, and the establishment of emission quotas for such an object in accordance with paragraph 7 of Article 5 of Law N 195 -FZ Table 3.1. Information on the results of accounting for the volume of intake (withdrawal) of water resources from water bodies and the volume of waste discharge, including drainage water, and their quality
I wrote more about providing information on the results of water intake and wastewater discharge here. Now, according to the information in the PEC report, if the required information is not provided, they may be held liable under Article 8.5 of the Code of Administrative Offenses of the Russian Federation.
These plates are filled out in the same way, with the only difference being that the data is taken from the draft VAT and wastewater treatment protocols. Data from the wastewater volume log is also used here.
This section is to be completed only for waste disposal facilities!
By Order of the Ministry of Natural Resources of the Russian Federation dated June 23, 2020 No. 383, tables 4.2 and 4.3 were also added to the PEC report:
Table 4.2. Information on the generation, recycling, neutralization, disposal of production and consumption waste for the reporting year 20__.
Table 4.3 . Information about legal entities and individual entrepreneurs from whom waste was received and (or) transferred
Providing a report on PEC through the personal account of the user of natural resources
In the personal account of the user of natural resources (entrance via the link - https://lk.fsrpn.ru/#/) it is possible to provide a report on industrial environmental control through the personal account of the user of natural resources.
To do this, your company must be authorized through an Unified Status Activity (USIA) account for a legal entity or individual entrepreneur.
Go to the MENU of your personal account.
Select the MENU item - YOUR REPORTING, then REPORTS ON PRODUCTION ENVIRONMENTAL CONTROL. We create a card and fill out all the required tabs.
The interface of your personal account is very clear, so I think there should be no difficulties filling it out.
Sanctions for serious violations
In case of violation of delivery deadlines or absence of reporting documentation, penalties have been developed for violators. The state motivates individual entrepreneurs or legal entities using the “stick method” to timely and high-quality reporting. Executive authorities now have quite a lot of levers for influence:
- Art. 13.19 of the Code of Administrative Offenses of the Russian Federation (any violation of deadlines is considered a violation of the procedure for submitting statistical reporting, and is subject to fines for an official in the amount of 20 thousand rubles, for a legal entity - in the amount of 70 thousand rubles);
- Art. 8.5 of the Code of Administrative Offenses of the Russian Federation (in case of distortion or deliberate concealment of information, the organization is subject to fines of up to 80 thousand rubles);
- Art. 8.2 of the Code of Administrative Offenses of the Russian Federation (concerns the interests of SMEs, the functioning of which leads to the generation of hazardous waste, implies an administrative suspension of work for up to 90 days or a fine of up to 250 thousand rubles);
- Art. 19.7 Code of Administrative Offenses of the Russian Federation (punishment for legal entities up to 5 thousand rubles)
Reporting of SMEs
How and when should documents be provided? Reports to Rosprirodnadzor in the environmental field are described in the federal order of the Ministry of Natural Resources (2010). The report has a notification function. Representatives of medium and small businesses that, as part of their activities, generate waste that poses a hazard to the environment should submit information. Such organizations report on their use, neutralization, placement, and transfer to other business entities.
Additions to the PEC report
If your enterprise is located in the cities: Bratsk, Krasnoyarsk, Lipetsk, Magnitogorsk, Mednogorsk, Nizhny Tagil, Novokuznetsk, Norilsk, Omsk, Chelyabinsk, Cherepovets, Chita, and it is on the list of objects for which emission quotas have been established - you must in accordance with paragraph 14 of Article 5 of Federal Law No. 195 “On conducting an experiment on quotas for pollutant emissions and introducing amendments to certain legislative acts of the Russian Federation in terms of reducing air pollution,” you will be required to include information in the PEC report for 2021 (not 2021!) on approved emission quotas, on the compliance of emissions at quota-bound facilities with such quotas, as well as on the implementation of action plans to achieve emission quotas.
Exemption from payments and reporting
Not all organizations are required to report, pay for environmental pollution and be registered with Rosprirodnadzor.
Such organizations are:
- office companies that produce only household waste;
- companies that have mobile rather than stationary sources of pollution.
The payment for environmental pollution is an environmental fee, a non-tax payment. Even if another company is engaged in garbage removal, the organization that produced the garbage pays for its creation.
Other organizations working with waste and environmental pollution are required to make timely payments and provide all forms of reporting.
Responsibility for the PEC report (fines)
If you fail to provide a response to the PEC or untimely submit a report on the PEC, as well as in the event of distortion of information in the PEC report, you may be held administratively liable under Article 8 of the Code of Administrative Offenses of the Russian Federation.
Code of Administrative Offenses of the Russian Federation Article 8.5. Concealment or distortion of environmental information Concealment, deliberate distortion or untimely reporting of data obtained during the implementation of industrial environmental control shall entail the imposition of an administrative fine on citizens in the amount of five hundred to one thousand rubles; for officials - from three thousand to six thousand rubles; for legal entities - from twenty thousand to eighty thousand rubles .
What is reflected in the documents
Environmental reporting forms are approved at the federal level. The document indicates the volume of waste, its classifier code, type, and hazard class. It is mandatory to attach copies of agreements on the transfer of hazardous substances and the license of the organization that receives the waste. In cases where an individual entrepreneur or organization does not transport or dispose of waste, this must be noted in the report. The document is sent to the technical specifications of Rosprirodnadzor.
Regional documents
Additional reporting is provided for SMEs that work in the field of handling various wastes related to regional supervision. It is provided in paper form to the regional department or its interdistrict departments.
Individual entrepreneurs and legal entities whose activities generate waste, including MSW, must provide information to the regional waste cadastre by March 1 of the current year. The following documents serve as the regulatory framework:
- Order of the Ministry of Ecology of the region.
- Resolution of the regional government.
Important points
What are the deadlines for submitting environmental reporting in the Russian Federation for entrepreneurs and commercial enterprises? There are several options for documents that they must fill out and submit to supervisory authorities in a timely manner. In 2021, environmental reporting included about ten different types related to environmental management. The volume depends on the specifics of the enterprise. Information can be provided in classic paper form, as well as in electronic form.
In the second case, environmental reporting is carried out using the natural resource user module, which is available on the Rosprirodnadzor website or on the Gosuslug portal.
