The environment is now at a stage of major change. This applies to everything - the principle of supervision and control is changing to risk-oriented, supervision is now carried out not over the enterprise as a whole, but over objects of negative impact, old forms of environmental documentation are becoming a thing of the past. As a result of these innovations, the routine part of environmental reality is also being transformed. Conventional environmental reporting is increasingly changing, and in this article we propose to look at these changes in more detail.
- General information: environmental reporting 2019
- Validity period of old permits
- What will happen to 2-TP air in 2021?
- Environmental reporting: 4-OS
- DVOS in 2021
- Payment for MSW and waste management
- New reporting on PEC in 2021
Who must submit the SME report for 2021 in 2021
The procedure for submitting reports was approved by Order of the Ministry of Natural Resources dated February 16, 2010 No. 30. The report is submitted by organizations and entrepreneurs - small and medium-sized businesses whose activities generate waste.
Waste is a substance or object that is generated in the process of production, performance of work, provision of services or in the process of consumption, which are disposed of, are intended for disposal or are subject to disposal in accordance with the Federal Law of June 24, 1998 No. 89-FZ “On Industrial Waste and consumption."
Depending on the degree of negative impact on the environment, waste is divided into five hazard classes in accordance with the criteria established by the federal executive body that carries out state regulation in the field of environmental protection:
- Class I - extremely hazardous waste;
- Class II - highly hazardous waste;
- Class III - moderately hazardous waste;
- Class IV - low-hazard waste;
- Class V - practically non-hazardous waste.
The regional departments of Rosprirodnadzor told Simplified magazine that SME reporting for 2021 must be submitted according to the old rules. Therefore, you need to submit a report, even if the company has ordinary office waste.
Starting from the report for 2021, the report must be submitted only by companies and individual entrepreneurs that operate at category III facilities (clause 5 of article 18 of Law No. 89-FZ as amended by Federal Law dated July 21, 2014 No. 219-FZ). The criteria by which an object is included in one category or another are defined in Government Resolution No. 1029 dated September 28, 2015. However, as Rosprirodnadzor explained to Simplified magazine, these rules are not applicable to the report for 2021.
The Simplified magazine advises to play it safe and submit a report. Rosprirodnadzor showed us how to fill out the form without errors, see the sample form.
Submission of reports to Rosprirodnadzor for 2021
All reporting is submitted through the natural resource user’s personal account - lk.fsrpn.ru
So, all SPDs for 2021 had to report no later than January 15, 2021. Exceptions - the departments of natural resources of the relevant constituent entities of the federation have established different reporting deadlines. They are indicated in acts issued by these authorities.
How to submit a report to Rosprirodnadzor? SPD has two stages of submitting the document to the regulatory authority - sending it in paper and electronic form.
For reference! The electronic version of the report must be registered before sending the paper version of the document. Therefore, it is necessary to submit a report to Rosprirodnadzor through government services in order to go through the identification procedure.
The report form is filled out using the “Environmental Management Module”. The procedure is as follows:
- Go to the official website of Rosprirodnadzor;
- Log in to it by clicking on the “log in through State Services” button;
- Install the specified module and use it to fill out the report form;
- Upload the created document from the program and upload it in the report preparation and submission section. The last thing at this stage is a unique identifier number.
Then the status changes, the system assigns an electronic number to the document. It must be stamped on paper, which, after printing, is sent to the territorial body of Rosprirodnadzor.
The document is sent by mail with a certified letter with acknowledgment of receipt. An electronic version of the report on any medium is attached to it. Typically, a CD can be provided.
Environmental reports in 2021
V.V. Putin signed a law that enshrines at the legislative level the rules on the duties of the authorities to encourage the separate collection of waste by various means. The document was published on the official portal...
Environmental reporting has changed slightly in 2021. Now there is no need to submit the 2-TP (air) report; adjustments have been made to form 4-OS (Rosstat order No. 473 dated 08/01/2018). In total, companies and individual entrepreneurs will need to submit about 20 reports to Rosprirodnazor, Rosstat, Rosvodresursy, Rosnedra.
Providing information in the field of waste management of hazard classes 1 - 5 for 2021 - Waste Log - until January 10
In accordance with Order of the Ministry of Natural Resources No. 721 dated September 1, 2011, enterprises and individual entrepreneurs are required to provide all documents related to the circulation of waste of hazard classes 1–5.
Waste management is taken into account for all individual branches, as well as for the enterprise as a whole. It is possible to maintain documents in electronic format and on paper. The data is stored for at least five years and is provided upon request of supervisory services.
Forms 3.1, 3.2, 3.3. Accounting for water intake, waste and drainage water discharge, and their quality for the fourth quarter of 2021 - until January 10
The forms are filled out in accordance with Order of the Ministry of Natural Resources of the Russian Federation No. 205 dated July 8, 2009. This reporting must be provided to citizens and companies that use water resources, collect and discharge them. Reporting is submitted to the regional department of Rosvodresursy at the end of the quarter. The deadline is until the 10th day after the reporting period. Therefore, information in paper or electronic form for the fourth quarter of 2021 is sent before January 10, 2021.
Report on the generation, use, neutralization and disposal of MSW and software for SMEs - until January 15
Reporting is submitted to the technical specifications of Rosprirodnadzor; you can fill out the report form on the Rosprirodnadzor website. The report is compiled for those types of waste that the enterprise or individual entrepreneur works with in accordance with Order No. 30 of the Ministry of Natural Resources of the Russian Federation dated February 16, 2010.
1-LH. Information on forest reproduction and afforestation - until January 15
This reporting is submitted by enterprises and individual entrepreneurs engaged in forest planting and growing planting material in nurseries. Reporting is generated on the basis of Rosstat Order No. 473 dated August 1, 2018, and is submitted to the territorial body of Rosstat by January 15, 2019 on paper or electronically.
12-LH. Information on forest protection – until January 15
The report is generated on the basis of Rosstat Order No. 473 of 08/01/2018, submitted to the territorial administration by 01/15/2019. This reporting must be submitted to companies and individual entrepreneurs who are engaged in the protection of forest objects from the harmful effects of insects and animals on forest lands and other lands territories.
Information report on the terms of subsoil use and materials of the license agreement - until January 20, February 5, March 1 and April 1
Reporting is provided on the basis of the provisions of Rosstat Resolution No. 43 of June 4, 2007. This report must be provided to organizations that use subsoil and hold licenses for geological surveys in the field of minerals. The report is submitted to the territorial department of Rosnedra.
2-TP (vodkhoz) – until January 22
Based on Rosstat Order No. 230 dated October 19, 2009, this report on the use of water resources is provided until January 22, 2019 for 2021. Reports are submitted to the territorial administration of Rosvodresursy by those organizations and individual entrepreneurs that use water bodies and the general water supply system , the daily catchment volume of which exceeds 50 cubic meters.
4-OS – until January 25
A report in Form 4-OS on expenses for protecting the natural environment is provided by enterprises and individual entrepreneurs that are required to provide for environmental protection measures and whose costs for these activities during the year exceed 100 thousand rubles. If a company has separate branches or divisions, then a report is prepared for everyone, and a general document for the organization is also presented. The contents of the report are determined by Rosstat Order No. 473 dated August 1, 2018.
Obtaining a comprehensive environmental permit for category 1 1-SPNA “Information on specially protected natural areas” - until January 25
Information about specially protected natural objects of national importance, nature reserves, reserves, arboretum zones, botanical gardens is provided to Rosstat by organizations that manage protected areas at the state level, as well as departments of subjects that manage zones at the regional level. The form and content of the report are prescribed in Rosstat Order No. 473 dated August 1, 2018.
2-OS – until January 25
A report on the conduct of water protection work is drawn up according to the 2-OS scheme on the basis of Rosstat Order No. 469 dated August 28, 2012. The report must be submitted to organizations and individual entrepreneurs specializing in water management and protection of water bodies.
2-TP. Waste – until February 1
Based on Rosstat Order No. 529 of 08/10/2017, a report on waste management is submitted to the Rosprirodnadzor RU by 02/01/2019. The report is provided by companies and individual entrepreneurs.
Declaration of payment for tax assessment – until March 10
Based on the Order of the Ministry of Natural Resources of the Russian Federation No. 3 dated January 09, 2017, NPA, a declaration on the NVOS payment is filled out by those organizations and individual entrepreneurs whose activities negatively affect the environment, except for objects of the 4th hazard category. Reporting is sent to regional offices of Rosprirodnadzor.
Report on observations of water bodies (form 6.1, 6.2, 6.3) – until March 15
Based on Order No. 30 of the Ministry of Natural Resources dated February 6, 2008, owners of water bodies, users of water resources, and authorized federal departments send information obtained from the monitoring of hydro facilities to the regional divisions of Rosvodresurs.
2-TP (hunting) – until March 21
This report is presented by individual entrepreneurs and organizations that use hunting objects under license and have entered into hunting agreements. If a legal entity has land in several regions of the country, then a report is generated for all of them to the regional branch of Rosstat.
PEC (industrial environmental control) program – until March 25
Provided on the basis of Order of the Russian Ministry of Natural Resources No. 74 dated February 28, 2018 by companies and individual entrepreneurs working at facilities of categories 1, 2, 3.
Declaration of the quantity of finished goods produced - before April 1
The declaration is filled out on the basis of Government Decree No. 1417 of December 24, 2015 for submission to Rosprirodnadzor by April 1, 2019 by those enterprises that manufacture and import products. The declaration is filled out not only for products, but also for packaging sent for disposal.
Report on the implementation of the plan for the elimination of waste generated during the use of products - until April 1
By Government Decree No. 1342 of December 8, 2015, companies and individual entrepreneurs producing and importing products are obliged to report on compliance with waste disposal limits. Summary data is accepted by Rosprirodnadzor from importers, territorial departments of the department - from product manufacturers (see list of Government Order No. 1886-r dated September 24, 2015)
Report on the availability of technical devices for recycling MSW and software - until April 1
The report is necessary for companies operating in the field of circulation of waste generated after the use of various products. The report contains the following data:
- Name, model, date of manufacture, purpose, type and manufacturer of technological equipment intended for disposal;
- Name of the disposal facility according to FKKO;
- Equipment location address;
- Details of the organization operating the equipment or individual entrepreneur.
The data is transferred to Rosprirodnadzor.
Report on the places where waste generated as a result of the use of finished products is collected – until April 1
The report is submitted by organizations and individual entrepreneurs involved in the management of waste of hazard categories 1–4, which are generated as a result of the use of various products. The report is submitted if there is a license for this type of activity. The form of the report is determined by Government Decree No. 1520. The report is submitted to Rosprirodnadzor.
Payment of the environmental fee and submission of an estimate of its amount - until April 15
The environmental fee is paid until 04/15/2019 on the basis of Government Decree No. 1073 of 10/08/2015 to Rosprirodnadzor. Mandatory for product manufacturers and organizations or individual entrepreneurs importing products that do not specialize in waste disposal. The environmental fee is carried out in relation to products provided for by Government Order No. 2970-r dated December 28, 2017.
Filling out the waste report form
To submit reports to Rosprirodnadzor on the website, you need to display the following data in the form provided:
- Legal name and address, other data that identifies SPD;
- Volumes of generated waste;
- Other legal entities and individuals to whom solid waste was transferred for storage, processing and disposal;
- Waste that is disposed of on SPD’s own territory.
The specified waste generated is necessarily divided into those that were disposed of, processed, neutralized, sent for burial or storage. Acceptance and transfer to other entities, which was carried out, must be confirmed by documents: agreements, acts of acceptance/transfer, certificates (on disposal, processing, burial).
Environmental reports in 2021
Federal environmental reporting 2021
In 2021, you need to submit about 10 types of reports in the field of environmental management, depending on the profile of the enterprise. It is allowed to provide information in traditional paper form or through electronic resources. In the latter case, this can be done through the natural resources user module (it is available for free on the Roprirodnadzor website) or the government services portal.
Report of SMEs – until January 15, 2021
The procedure for submitting environmental reporting is established by Order No. 30 of the Ministry of Natural Resources dated February 16, 2010. Reporting is of a notification nature, it is required to be sent by representatives of small and medium-sized businesses, during whose work waste is generated, or they use it, neutralize it, dispose it, or transfer it to other business entities , received from the latter, disposed of.
The documents reflect the volume of waste, its type, classifier code, and hazard class. Attached are copies of waste transfer agreements and licenses from the receiving party, if the organization or individual entrepreneur does not themselves transport and dispose/dispose of waste. The report of SMEs is sent to the Office of Rosprirodnadzor for the Republic of Tatarstan.
2-TP (air) – until January 22, 2021
The form for sending information and the procedure are established by Rosstat order No. 661 dated November 8, 2021. Are there stationary sources of emissions on the balance sheet? It is necessary to send information about the protection of atmospheric air to the Office of Rosprirodnadzor for the Republic of Tatarstan.
2-TP (vodkhoz) – until January 22, 2021
Similar to the report 2-TP (air), the procedure is established by Rosstat order No. 230 dated October 19, 2009 and is submitted to the Water Department. It applies to water users with daily water consumption of 50 kum. m depending on the activity profile.
4-OS – until January 25, 2021
If there are wastewater treatment plants, you pay for the negative impact on nature, and implement measures aimed at protecting the environment, then you need to report on expenses in this area. Reporting is regulated by an order of Rosstat (as well as in forms 2-TP air and water management) and is sent to the Rosstat technical specifications.
2-TP Waste – until February 1, 2021
This type of reporting is regulated by Order No. 529 dated August 10, 2021. The report is submitted by legal entities 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 payment for tax assessment – until March 10, 2021
The procedure and form of presentation were approved by order of the Russian Ministry of Natural Resources dated January 9, 2021 No. 3.
The report is required to be provided by legal entities and individual entrepreneurs whose work generates waste, as well as whose activities have a negative impact on the environment. The exception is objects of hazard category IV, namely those that simultaneously have the following criteria:
- The volume of emissions into the atmosphere from stationary sources is no more than 10 tons annually. The emissions do not contain radioactive substances and substances of hazard classes I and II;
- There are no discharges of pollutants into the drainage system or into the environment;
- The design thermal power of energy, gas or steam equipment at the enterprise does not exceed 2 Gcal/hour;
- The equipment is used for research purposes (pilot production organizations, research institutes, experimental design bureaus).
The declaration is submitted to the technical authority of Rosprirodnadzor at the location of the objects of negative impact. If they are located in different regions, then it is necessary to prepare declarations for each object and send them to the appropriate technical specification.
The declaration indicates the calculation of the amount of payment that must be paid to the budget for emissions, discharges and waste disposal.
Declaration of goods sold in the Russian Federation subject to subsequent disposal - until April 1, 2021
The declaration is submitted to the technical specifications of 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. The declaration indicates the name of the product, its code according to the generally accepted classification, weight (in kg) and quantity.
Report on compliance with waste disposal standards from product use - until April 1, 2021
The form must be filled out and submitted to the TU or the central office (in the case of importing goods) by product manufacturers and importers. The obligation to comply with recycling standards and submit relevant reports is established by government decree No. 1342 of December 8, 2015.
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 Commodity Nomenclature of Foreign Economic Activity of the EAEU, 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.
Payment of the environmental fee and submission of an estimate of its amount – until 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. Such a list was approved at the legislative level by Government Order No. 1886-r dated September 24, 2015. The form for calculating the amount is determined in the order of Rosprirodnadzor dated August 22, 2021 No. 488.
Payments and settlements for them are sent to Rosprirodnadzor or its technical specifications.
Regional environmental reports for 2021
Reporting has been established for SMEs operating in the field of waste management and subject to regional supervision. It is provided in paper form from January 1 to March 1 according to the order of the Ministry of Ecology of the Republic of Tatarstan directly to the regional department or to its interdistrict departments.
Legal entities and individual entrepreneurs whose work generates waste (including MSW) are required to submit information to the regional waste cadastre. The deadline for sending the report is March 1.
Sanctions for failure to submit environmental reports or violation of their deadlines
The legislator motivates organizations and individual entrepreneurs to submit reports on time using the whip method - threatening penalties if the order is violated.
The regulatory authorities have enough leverage:
- Art. 13.19 Code of Administrative Offenses of the Russian Federation. Failure to provide information or its submission after the expiration of the established period is regarded as a violation of the procedure for submitting statistical reporting and is punishable by penalties for legal entities of up to 70 thousand rubles, for officials - up to 20 thousand rubles;
- Art. 8.5 Code of Administrative Offenses of the Russian Federation. According to this norm, a violation is regarded as a deliberate concealment or distortion of environmental information. Fine - up to 6 thousand rubles for the responsible person in the organization and up to 80 thousand rubles - for the enterprise itself;
- Art. 8.2 Code of Administrative Offenses of the Russian Federation. Affects SMEs whose operations generate waste. Sanctions - up to 30 thousand rubles for a responsible employee, up to 250 thousand rubles or administrative suspension of activities for a period of up to ninety days - for an organization, up to 50 thousand rubles or administrative suspension of activities for a period of up to ninety days - for individual entrepreneurs;
- Art. 19.7 Code of Administrative Offenses of the Russian Federation. If the inspector regards it as failure to provide information, if its submission is required by law, then the violator will face the most “mild” punishment - up to 500 rubles for an official, up to 5 thousand rubles for a legal one.
