Bartholomy - Environmental Law and Practice in The Russian Federation Overview

Environmental law and practice in the Russian Federation:..., Practical Law Country...
Environmental law and practice in the Russian

Federation: overview
by Marc Bartholomy, Ella Omelchenko, Dmitrii Tolkachev and Maria Chivragova,
Clifford Chance
Country Q&A | Law stated as at 01-Jun-2020 | Russian Federation
A Q&A guide to environmental law in Russia.
This Q&A provides a high-level overview of environmental law and practice, and looks at key practical
issues including emissions to air and water; environmental impact assessments; waste; contaminated land and
environmental issues in transactions.
Environmental regulatory framework
1. What are the key pieces of environmental legislation and the key regulatory authorities?
Legislation
Russia has a federal legal system with environmental matters regulated at both the federal and regional level. At the
federal level, this takes the form of codes, laws and subordinate regulations approved by the government and other
state bodies. These are supplemented further at the regional level.
Codes and federal laws cover matters such as:
• Environmental protection, including environmental expert assessment and so on.
• Use of natural resources (including land, subsoil, forests, water and so on).
• Sanitation and epidemiology.
• Waste management.
• Wildlife protection.
• Activities on the continental shelf and in the territorial sea.
• Nuclear power.
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Many aspects of environmental law, for example, industrial emissions, are regulated in government decrees and
federal authorities' orders.
Finally, there are also technical regulations on specific aspects of the environmental protection and pollution control
regimes. These include:
• Sanitary and hygiene standards and requirements (SANPIN).
• Hygienic norms (GN).
• Technical regulations.
• Construction rules (SP).
• Construction norms and rules (SNIP).
• State standards (GOST).
Regulatory authorities
The Russian Ministry of Natural Resources and Ecology is the federal policymaker for matters related to the
study, use, renewal and protection of natural resources, environmental monitoring, pollution control and waste
management.
The ministry co-ordinates and supervises the activities of five subordinate agencies which are the:
• Federal Service for Supervision of Natural Resource Usage (Rosprirodnadzor).
• Federal Agency for Water Resources (Rosvodresursy).
• Federal Forestry Agency (Rosleskhoz).
• Federal Agency for Subsoil Use (Rosnedra).
• Federal Service for Hydrometeorology and Environmental Monitoring (Rosgidromet).
The Federal Environmental, Industrial and Nuclear Supervision Service (Rostechnadzor) is the federal policymaker
for matters related to technological and nuclear supervision.
Regulatory enforcement
2. To what extent do regulators enforce environmental requirements?

A breach of the environmental legislation can result in civil and/or administrative liability for the individual or legal
entity responsible. Individuals responsible may face criminal penalties.
In recent years, the Russian Government has been prioritising environmental matters in its policy. Rosprirodnadzor
has reported an increase in inspections and successful enforcement of environmental regulations. While there are
still issues with enforcement of the environmental legislation in some regions of Russia, Rosprirodnadzor) has
reported greater efficacy of various enforcement measures, resulting in less harm to the environment.
Environmental NGOs
3. To what extent are environmental non-governmental organisations (NGOs) and other pressure
groups active?
There are a number of environmental NGOs that actively participate in major environmental projects and initiatives,
including with respect to improvement of the Russian environmental legislation.
Some of these organisations are well-known and operate worldwide, such as Greenpeace and the World Wildlife
Fund. Other NGOs are national, such as the Russian National Committee for Supporting UNEP, or regional, such
as Baikal Research Centre.
Under Russia's environmental legislation NGOs can carry out environmental monitoring, and Russia's authorities
must consider the results of such monitoring.
NGOs also have the right to file complaints with government authorities and initiate legal proceedings to:
• Cancel decisions on design, development, renovation/overhaul or use of facilities and sites that may
negatively impact the environment.
• Restrict, suspend or terminate any activity that may be harmful to the environment.
Construction and industrial development projects that affect the environment are increasingly being criticised or
challenged by NGOs and other pressure groups. However, actions by such groups generally have little influence on
government decisions.
However, there have been cases where environmentally harmful projects have been halted due to public pressure.
For example, in 2019 a local group raised environment-related concerns with the environmental prosecutor's office
regarding a new drinking water bottling plant being built near Lake Baikal. As result of the complaint, the prosecutor
filed several lawsuits in Russian state courts. The courts found in favour of the prosecutor and issued a number of
landmark decisions halting construction .
Environmental permits

4. Is there a permitting regime for polluting emissions to land, air and water? Can companies apply for
a single environmental permit for all activities on a site or do they have to apply for separate permits?
Single/separate permits
As of 1 January 2019, in the context of broader reform of government oversight of various sectors, Russia's
environmental permitting regime was revised, with:
• An integrated permitting regime being introduced for the heaviest-polluting industrial facilities.
• Simplification/abolition of permitting procedures for other categories of emitting facilities.
This new regime is based on the existing classification of all emitting facilities into one of four categories, ranging
from I to IV (that is, from highest to lowest environmental impact), with different levels of regulatory obligations
for each category.
From 1 January 2019, Category I facilities are obliged to obtain a single integrated environmental permit instead
of three separate permits (for emissions to air, wastewater discharge and solid waste disposal). This must be done
during the transitional period until 1 January 2025. For certain facilities there is an even tighter deadline (see
Question 5).
Category II facilities do not require a single integrated environmental permit. Instead, the applicants must submit
a "declaration on environmental impact" to Rosprirodnadzor. The declaration remains valid for a period of seven
years. If any element of the facility that could adverse environmental impacts (for example, plant and equipment)
is changed or modified, , the declaration must be updated.
For Category III and IV facilities there is no obligation to obtain environmental permits or submit declarations on
environmental impact.
5. What is the framework for the environmental permitting regime?
The integrated permitting regime is generally regulated by Federal Law No. 7-FZ On Environmental Protection,
dated 10 January 2002 (Environmental Protection Law) and an implementing government decree.
There is a list of 300 Category I facilities , which account for 60% of Russia's total pollutant emissions and which
are required to obtain an integrated environmental permit by 31 December 2022.

Other Category I facilities must obtain an integrated environmental permit by 1 January 2025.
Permits and regulator
An integrated environmental permit is issued to a company to operate a particular facility that makes emissions (for
example, a manufacturing plant or a pipeline that may include one or more points of discharge).
The local offices of Rosprirodnadzor are tasked with issuing integrated environmental permits.
Before filing an application for an integrated environmental permit with Rosprirodnadzor, a state ecological expert
review (SEER) report in relation to the application materials must be obtained (see Question 17).
The statutory time frame for integrated environmental permits to be issued is one month from the date of the
application.
Length of permit
Integrated environmental permits are initially granted for a seven-year period and can be extended by a further
seven years if the following conditions are met:
• Actual emissions are within the levels allowed under the integrated environmental permit.
• The applicant complies with its reporting obligations, including filing regular reports and accident reports.
• An eco-efficiency improvement programme (where applicable) is implemented in line with the approved
schedule.
If any changes are made at the facility (to the technology and/or equipment and/or raw materials, for example)
which result in a change of emission levels beyond those specified in the integrated environmental permit, a revised
integrated environmental permit must be obtained.
Restrictions on transfer
On transfer of ownership rights to the facility, the integrated environmental permit must be amended to reflect the
new owner.
The local offices of Rosprirodnadzor have 15 calendar days from the date of the relevant application to issue a revised
integrated environmental permit.
Penalties
Companies that operate Category I facilities without an integrated environmental permit can incur an administrative
fine of up to RUB100,000 (about EUR1,200 as of 1 April 2020).
Failure to comply with permitted levels of emissions over a period of six consecutive months can result in cancellation
of the integrated environmental permit by court decision, based on a claim filed by Rosprirodnadzor.
Water pollution and abstraction

6. What is the regulatory regime for water pollution (whether part of an integrated regime or
separate)?
Discharges into the environment
From 1 January 2019, the regulatory regime for water pollution discharged directly into the environment is part of
the integrated regime.
For more detail on integrated environmental permits, see Question 4 and Question 5.
Discharge into central sewage systems
A separate regulatory regime applies to wastewater discharged into a central sewage system. In such cases an
agreement with the respective utility company must be concluded. A separate permit for environmental pollution
is not required .
Prohibited activities
It is generally prohibited to:
• Discharge wastewater into the environment without a permit.
• Discharge prohibited substances with waste water.
• Exceed any prescribed emission limits.
Clean-up/compensation
The party responsible must fully compensate the harm caused to the environment. There are special regulations
setting out rates and methods of calculating such compensation based on the extent of the environmental harm
caused.
Penalties
Penalties for water pollution may include civil, administrative or criminal penalties.

Companies that discharge substances in violation of the law can incur an administrative fine of up to RUB100,000
(about EUR1,200 as of 1 April 2020) or have their activities suspended for up to 90 days.
The individuals responsible may face criminal penalties, which vary depending on the severity of the consequences
of the violation. Such penalties can include a fine or disqualification from engaging in certain professional activities
for up to five years, or a prison term of up to five years (if the violation resulted in any fatalities).
7. What is the regulatory regime for water abstraction (whether part of an integrated regime or
separate)?
Extraction of groundwater for commercial purposes requires a licence. Licences are issued by the relevant local
division of the Federal Agency for Subsoil Use (Rosnedra) or relevant regional authorities.
A licence is not required if the:
• Water is used not for commercial purposes (that is for household or similar needs).
• Volume of water extracted does not exceed 100 cubic metres per day.
• Water is extracted from aquifers that are not used for centralised water supply.
The extraction of groundwater for commercial needs without a licence is prohibited.
Compensation
See Question 6.
Penalties
In the case of groundwater use without a licence, a company can incur an administrative fine of up to RUB1 million
(about EUR12,000 as of 1 April 2020).
In more serious cases, the individuals responsible may face criminal penalties. Such penalties may include, in
particular, a fine of up to RUB500,000 (about EUR6,000 as of 1 April 2020) or a prison term of up to five years.
Air pollution

8. What is the regulatory regime for air pollution (whether part of an integrated regime or separate)?
From 1 January 2019, the regulatory regime for air pollution is part of the integrated regime.
• Pollute or otherwise produce any adverse physical impact on the air without a permit.
• Release any prohibited substances into the air.
• Exceed any prescribed emission limits.
Clean-up/compensation
The responsible party must fully compensate the harm caused to the environment. There are special regulations
setting out rates and methods of calculating such compensation based on the extent of the environmental harm
caused.
Penalties
Penalties for air pollution include civil, administrative or criminal penalties.
Companies can incur an administrative fine of up to RUB250,000 (about. EUR3,000 as of 1 April 2020) or have
their activities suspended for up to 90 days.
In more serious cases, the individuals responsible may face criminal penalties, which vary depending on the severity
of the consequences of the violation. Such penalties may include a fine, or disqualification from engaging in certain
professional activities for up to five years, or for a prison term of up to five years (if the violation resulted in any
fatalities).
Climate change

9. Is your jurisdiction party to the United Nations Framework Convention on Climate Change
(UNFCCC), the Kyoto Protocol and/or the Paris Agreement? How are the requirements under those
international agreements implemented or being implemented?
Russia is a party to the United Nations Framework Convention on Climate Change and the Kyoto Protocol to the
United Nations Framework Convention on Climate Change (Kyoto Protocol).
The following steps have been taken in implementation of the Kyoto Protocol:
• A national regulatory framework for monitoring GHG emissions is under development (see Question 10).
• A framework for investment projects to reduce GHG emissions has been created.
• Russian officials have reported a 37% reduction in the country's GHG emissions over the past 20 years (and
31% against the 1990 baseline, which is in line with Russia's commitments under the first phase of the Kyoto
Protocol).
Although Russia has opted out of the second phase of the Kyoto Protocol, it is a party to the Paris Protocol to the
United Nations Framework Convention on Climate Change 2015 (Paris Agreement) ratified by Government Decree
No. 1228 of 21 September 2019.
Under its general policy on reduction of emissions, the Russian government is currently developing a complex legal
framework to limit GHG emissions. In particular, a separate permitting regime and levies are proposed. For further
details, see Question 40.
10. Are there any national targets or legal requirements for reducing greenhouse gas (GHG) emissions?
How far are the targets aligned with the 1.5 degree target in the Paris Agreement, if at all? Has a climate
emergency been declared? Is there a national strategy on climate change?
National strategy
There are several policy documents setting out the Russian government's strategy on renewable energy generation
and use and on increasing energy efficiency.
Plan for reduction of greenhouse gas emissions

In early 2020, the Russian Ministry of Economic Development prepared a draft of a new strategy for the period to
2050 which sets the goal of reducing GHG emissions to two-thirds of the 1990 level by 2030.
To reach this goal, the government has:
• Drafted a framework document setting out the types of regulations to be adopted at the national level in
order to establish GHG emissions monitoring system. However, to date most of these regulations have yet to
be enacted.
• Prepared draft amendments to the Environmental Protection Law which would create a legal framework to
impose restrictions on GHG emissions and offer economic incentives to companies for reducing emissions.
However, this legislative initiative remains in draft form, and it is unclear if, and when, it will be enacted. For
further details, see Question 40.
11. Do any emissions/carbon trading schemes operate?
There are two main schemes for carbon trading:
• Carbon trading under Article 6 of the Kyoto Protocol.
• The voluntary carbon market.
Article 6 of the Kyoto Protocol
Carbon trading under Article 6 of the Kyoto Protocol provides a framework for investment projects to reduce GHG
emissions. The process consists of three stages:
• Application stage.
• Implementation of the project.
• Transfer of the emission reduction units.
If a company wishes to participate in a GHG emissions reduction project, it must apply to the Russian Ministry
of Economic Development for approval of the investment project (special design documentation for the project,
prepared in accordance with international standards, must be included with the application). The project is assessed
by Sberbank of Russia, the country's leading commercial bank. Sberbank then issues a report containing its findings
to the Ministry of Economic Development. If the bank's assessment is positive, the ministry approves the project
and notifies the Ministry of Natural Resources and Ecology, the applicant, Sberbank and the Russian Fund for
Information on Natural Resources and Environmental Protection which maintains a register of such investment
projects.

The applicant must submit progress reports annually on implementation of the project. Such reports are subject
to independent assessment. If assessment of the project implementation is positive, the proceeds from the GHG
reduction will be transferred to the investor of the project.
Voluntary carbon market
There is no developed mechanism for voluntary carbon trading in Russian legislation. However, at least two
companies (Arkhangelsk Pulp and Paper Mill and Arkhangelsk Sawmill No. 25) have voluntarily decreased their
carbon emissions under the "verified carbon standard" (a global standard for emission reduction and removal
projects and programmes, created by the VCS Association) and sold the verified carbon units (that is, units each
representing a reduction of one tonne of carbon dioxide equivalent (CO2e)) to Eco Securities and Land Rover.
Renewable energy
12. Are there any national targets or legal requirements for increasing the use of renewable energy
(such as wind or solar power)? Is there a national strategy on renewable energy?
Energy strategy to 2030
The Russian Energy Strategy for the Period to 2030 (approved by Government Directive No. 1715r, dated 13
November 2009) establishes the following goals for renewable sources of energy:
• By 2020 the share of electricity produced from renewable energy sources is to be increased from 0.5% to
4.5%.
• Between 2020 and 2030 the share of renewable energy is to be increased further, so that by 2030 it accounts
for 80 to 100 billion kilowatt hours (kWh) per year.
• Increased reliance on renewable sources of energy is expected to contribute to more rational use of natural
resources and improved public health and quality of life.
• A range of incentives will be offered to enhance the development of Russia's renewable energy sector.
Tax incentives
Beginning on 1 January 2021 and continuing up to 1 January 2029, individuals will be exempted from paying
income tax on revenues from selling electricity generated using so-called microgeneration units, defined as facilities
functioning on the basis of, among other things, renewable sources of energy (such as solar batteries), with a
maximum generation capacity of 15 kWh which do not involve any electrical equipment used for servicing more than
a single premises in a building.

13. Do any renewables support schemes operate?
Russian electrical energy industry law provides economic and organisational measures supporting the use of
renewable energy sources, including:
• State subsidies covering part of the costs of connecting the renewable energy generating facility to the power
grid.
• Pricing stimuli for enhanced use of renewable energy.
• Tax incentives.
Energy efficiency
14. Are there any national targets for increasing energy efficiency (for example, in buildings and
appliances) or legal requirements for achieving energy efficiency standards? Is there a national
strategy on energy efficiency?
Russian energy efficiency policy is based on Federal Law No. 261-FZ On Energy Conservation and Increasing Energy
Efficiency, dated 23 November 2009 (Energy Efficiency Law) and the Russian Energy Strategy for the Period to
2030.
The goal of Russia's energy policy is to make the most effective use of the country's natural energy resources and
the potential of the energy sector for sustainable economic growth, improving the quality of life of the country's
population and helping to strengthen its foreign economic position.
Energy Efficiency Law
The Energy Efficiency Law envisages, among other measures:
• Compulsory energy assessment of buildings and industrial facilities in certain industries(for example, state-
owned companies, natural monopolies and companies in the oil and gas sector).
• Buildings (except buildings for designated cultural heritage sites, temporary structures, auxiliary buildings
and a few other exceptions) must be built/refurbished in accordance with energy efficiency standards.

• Terms and conditions of "energy service" agreements (that is, a service and supply agreement under which
existing equipment is upgraded and metering devices are installed as necessary to ensure energy savings and
higher energy efficiency).
• Monitoring compliance with energy conservation and energy efficiency standards. Companies that fail to
comply with such standards can be fined up to RUB600,000 (about EUR7,000 as of 1 April 2020).
15. Do any mandatory or voluntary labelling schemes exist to identify energy efficient goods or
buildings?
Domestic appliances, including refrigerators, TVs, washing machines and so on and passenger lifts must contain
information about the energy efficiency class on their labelling and supporting technical documentation.
Buildings and other structures (with limited exceptions, such as cultural heritage sites, religious buildings, individual
homes) must comply with energy efficiency requirements that relate to energy consumption rates, and construction
specifications and technical solutions. Apartment buildings must have energy efficiency labelling.
16. Do any energy efficiency support schemes operate?
See Question 14.
Environmental impact assessments
17. Are there any requirements to carry out environmental impact assessments (EIAs) for certain types
of projects?
Scope
Under Russian law, the EIA process is a nationally prescribed process effectively consisting of two separate stages:

• EIA of a proposed project, which is typically prepared with the assistance of environmental consultants.
• Further assessment of the proposed project and of the results of the EIA through state ecological expert
review (SEER).
The SEER is an overall environmental assessment of a project and the EIA results. The EIA report is therefore a
prerequisite to the SEER, and a project must comply with both the EIA and the SEER.
The EIA and SEER are required, in particular, for the following types of projects/documentation:
• Production sharing agreements.
• Any documentation, including design documentation, related to activities to be carried out on the
continental shelf of the Russian Federation or within the country's exclusive economic zone or territorial sea
(for example, pipeline construction, drilling and extraction of natural resources, and the creation of artificial
islands).
• Design documentation for construction projects within protected natural areas.
• Design documentation for construction projects for waste management facilities.
• Design documentation for artificial islands to be created within major (that is, federal) bodies of water.
• Design documentation for construction of Category I facilities or draft application dossiers for obtaining an
integrated environmental permit (see Question 4 and Question 5).
Depending on the type of project, the SEER is carried out either by Rosprirodnadzor or by the relevant regional
authorities.
Penalties
A positive SEER is required in order to obtain state or private financing to implement such projects. No activity can
be carried out until a positive SEER is obtained.
In addition, non-compliance with SEER requirements may result in an administrative fine and civil liability for the
company.
Habitats and biodiversity
18. What requirements and regimes apply for the conservation of nature, habitats and biodiversity that
affect development? What assessments or obligations are required before any development begins?

Requirements and regimes
Russia is a party to, among other things, the:
• UN Convention on Biological Diversity (CBD).
• Convention on Wetlands of International Importance (the Ramsar Convention).
• Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
Prior assessments and obligations
At the national level, Russian legislation establishes a regime governing specially protected natural areas. Depending
on the type of area, construction within them may be restricted or prohibited. Where construction is possible, the
design documentation must undergo an EIA (see Question 17).
Waste and the circular economy
Regulatory regime
19. What is the regulatory regime for waste?
Russian legislation divides waste into five classes, ranging from Class I (extremely hazardous) to Class V (non-
hazardous).
All companies must determine the type of waste they generate and prepare a special document ("passport") for waste
of Classes I to IV.
Under Russian law, a licence is required for the collection, transportation, handling, recycling or dumping of waste
of Classes I to IV. Companies that generate waste are generally not required to obtain a licence. Instead, they must
enter into an agreement on waste disposal with a specially licensed company.
Companies operating Category I and II facilities are required to apply for a waste "limit" (essentially a permitted
volume of waste). For Category I facilities, waste limits are specified in the integrated environmental permit. For
Category II facilities, waste limits must be obtained before preparing the declaration on environmental impact.
Category III facilities must make periodical returns to Rosprirodnadzor or the respective regional environmental
authorities detailing the waste they generate. For Category IV facilities, there is no obligation to obtain preliminary
approval of projected amounts of waste or to report on volumes actually generated.

• Collect, transport, handle, recycle or dump waste without a licence.
• Dispose of waste without approved waste limits.
• Exceed the approved waste limits.
Operator criteria
Companies that operate waste disposal sites or engage in waste transportation, handling or recycling must obtain a
licence and comply with certain requirements (for example, with regard to the necessary facilities and equipment,
and employees' technical competence as confirmed by the relevant training certificates).
Special rules for certain waste
Special rules are established, in particular, for:
• Municipal solid waste.
• Motor transport
• Various types of goods that are subject to compulsory recycling (such as tyres and consumer electronics).
• Nuclear waste.
• Biological waste.
• Medical waste.
Penalties
Violations related to waste disposal may result in civil, administrative or criminal penalties.
Companies that unlawfully dispose of waste can incur an administrative fine of up to RUB600,000 (about EUR7,000
as of 1 April 2020) or have their activities suspended for up to 90 days.
The individuals responsible may face criminal penalties, which vary depending on the severity of the consequences
of the violation. Penalties may include a fine, or a prison term of up to five years (if the violation resulted in injury),
or up to eight years (if the violation resulted in any fatalities or the spread of disease).
National strategy, targets and producer responsibilities

20. Is there a national strategy to tackle particular types of waste (such as plastics waste or marine
litter)? What waste targets exist? What producer responsibility schemes exist?
National strategy
In recent years, the Russian government has approved strategy documents for solid municipal waste management
and for development of waste recycling industry to 2030.
• However, there is no national strategy to tackle particular types of waste.
Asbestos
21. What is the regulatory regime for asbestos?
Russia is a party to the Asbestos Convention 1986 concerning safety in the use of asbestos.
The regulation of asbestos in Russia is not uniform or codified. Various safety requirements applicable to the use
of asbestos, limitation of the use of asbestos, and mandatory reduction of environmental pollution by asbestos are
found in various Russian legislative acts and decrees.
These requirements include a maximum concentration of airborne asbestos dust and various occupational health
and safety requirements. In addition, there are requirements dealing with asbestos-containing materials in buildings
during their construction, repair or demolition. This is mainly intended to minimise the emission of asbestos dust
during relevant works.
Other requirements include:
• Sanitary control and monitoring in the workplace,
• Sampling, measurement and monitoring of asbestos dust.
• Medical examinations of workers.
Additional holiday entitlements and early retirement are also envisaged for employees who carry out asbestos-
related work.

There is no total prohibition on the use of asbestos in Russia. However, there are certain restrictions on its use in
certain situations. For example, it is prohibited to use insulating material containing asbestos when building boats
and ships.
Main obligations
The main obligations to ensure safety in handling asbestos rest with employers. They must ensure, among other
things, that:
• Workplaces are safe.
• Levels of asbestos dust are regularly measured and sampled.
• Employees undergo regular medical examinations.
• Qualified personnel are employed.
• The necessary protective and safety equipment is provided.
• Employees are informed of the risks associated with hazardous activities.
• Investigations are conducted where necessary.
• Steps are taken to prevent accidents.
Facilities that engage in production of processed asbestos fibres, asbestos-based mixtures and products made
from them, and products containing asbestos cement or fibre cement, are classified as Class II (for details on the
classification of emitting facilities, see Question 4 and Question 5). Such facilities must submit a declaration on
environmental impact to Rosprirodnadzor.
Penalties
There are both administrative and criminal penalties for failure to comply with the statutory requirements.
Companies that violate statutory restrictions on handling asbestos can incur an administrative fine of up to
RUB250,000 (about EUR3,000 as of 1 April 2020) or have their activities suspended for up to 90 days. An
administrative fine of up to RUB80,000 (about EUR950 as of 1 April 2020) may also be imposed for failure to submit
a declaration on environmental impact.
If the violation results in an epidemic, the individual responsible may face criminal penalties, including a fine, or
disqualification from engaging in certain professional activities for up to three years, or a prison term of up to five
years (if the violation has resulted in any fatalities).

Contaminated land
22. What is the regulatory regime for contaminated land?
Regulator and legislation
Oversight functions with respect to land are allocated among several regulatory authorities, including the:
• Federal Service for Supervision of Natural Resource Usage (Rosprirodnadzor).
• Federal Service for State Registration, the Cadastre and Cartography (Rosreestr).
• Federal Service for Veterinary and Phytosanitary Monitoring (Rosselkhoznadzor).
A special legislative framework is in place for improving the quality and fertility of agricultural land. Special hygienic
norms establish the maximum permitted levels of chemicals in soils.
Key obligations of an owner/occupier of land include:
• Preventing the pollution of land.
• Protecting land from various impacts including erosion, mudflow, flooding, saturation, secondary salination,
drying, compaction, pollution from industrial waste or post-consumer waste and so on.
• Performing restorative measures, where the above obligations are breached (for example, remediation (see
Question 23) or restoring the fertility of agricultural land).
Remediation of accumulated environmental harm on abandoned sites
In 2016, special framework legislation was adopted addressing identification and remediation of historical
contamination of sites that have been abandoned ("accumulated harm to the environment", which also includes
contamination of land). Since 2017, Russian federal, regional and municipal authorities have been required to
identify abandoned sites where pollutants/waste from former activities remain. At the next stage, the competent
authorities must organise the necessary work to remediate the environmental damage.
Investigation and clean-up
Generally, land contamination can be discovered by the regulatory authorities following a visit to a site, based on
soil tests confirming the contamination. The relevant procedures include:

• An on-site inspection by the authorities, that is, physically accessing a company's site. Such inspections are
subject to certain procedural requirements (for example, the company's representatives must be present
during the inspection).
• Site observation by the authorities, which does not require access to the company's site (for example,
observing from the perimeter of the site). However, penalties cannot be imposed solely based on site
observation; if there are indications that an offence has been committed, the authorities must arrange an on-
site inspection.
For details of liability in relation to clean-up, see Question 23.
Penalties
Depending on the severity of the consequences of the violation, administrative or criminal liability may be
imposed on the responsible party. However, under Russian law legal entities cannot be subject to criminal liability.
Accordingly, a company may face administrative penalties, while in cases of a more severe violation that constitutes
a crime (see below) penalties will be imposed on the individuals responsible.
Administrative penalties on companies responsible for contaminating land include a fine of up to RUB80,000 (about
EUR950 as of 1 April 2020) or suspension of the company's activities for up to 90 days. Failure to remediate the land
voluntarily is also punishable with an administrative fine of up to RUB700,000 (about EUR8,200 as of 1 April 2020).
If the violation has resulted in severe damage to the environment or injury or death, the individuals responsible may
face criminal penalties. Penalties vary depending on the severity of the consequences of the violation. Such penalties
may include, in particular, a fine, or disqualification from engaging in certain professional activities for up to three
years (if the violation resulted in injury), or a prison term of up to five years (if the violation resulted in any fatalities).
23. Who is liable for the clean-up of contaminated land? Can liability be excluded in transactions?
Liable party
Under Russian law, a party that harmed the environment as a result of an environmental violation (for example,
through pollution or deterioration of soil quality) must compensate the harm caused in full. To do so, the responsible
party may be required to do one or more of the following:
• Perform a clean-up.
• Pay monetary compensation to the state based on statutory calculation methods and rates.
For details of the administrative/criminal penalties imposed for violations of environmental law, including land
contamination, see Question 22. The same party will also be obliged to compensate for harm caused to the
environment resulting from that violation.

Under the Russian Civil Code, if several parties are found responsible, they will be jointly and severally liable.
In cases of historical contamination (that is, if there is no financially solvent party and pollutants/waste from former
activities remain on site), the clean-up may be carried out by the Ministry of Natural Resources and Ecology or the
relevant regional or municipal authorities (see Question 22).
Any harm caused to a third party's property or health must be compensated in full, separately from compensation
of the environmental harm caused (see Question 25).
Owner/occupier liability
The owner/occupier of contaminated land may be found liable, based on the general rules for liability (see above,
Liable party).
Previous owner/occupier liability
A previous owner/occupier of a land plot can potentially be held liable based on the rules applicable to owners/
occupiers if it can be proved that the contamination occurred during the period of ownership or occupation (see
above, Liable party). However, this is likely to be difficult to prove. Russian state courts often do not delve into the
details of liability for contamination, so there is a risk that they will not properly examine the previous owners'/
tenants' involvement.
Limitation of liability
The limitation period for claims related to compensation for harm caused to the environment is 20 years.
Voluntary clean-up programme
There are no programmes that incentivise the voluntary clean-up of contaminated land by third parties.
24. Can a lender incur liability for contaminated land and is it common for a lender to incur liability?
What steps do lenders commonly take to minimise liability?
Minimising liability
A lender cannot be held liable for the contamination of land. As a general rule, the person that caused the loss or
damage bears liability for it.
At the same time, in cases where a loan is provided for narrowly-defined purposes and the conditions for granting
the loan require that the borrower comply with environmental rules, lenders sometimes require borrowers to
confirm their compliance with environmental requirements and, in case of violation, suspend the financing (for
example, in the spheres of energy and resource conservation, climate projects, renewable energy and energy-efficient
construction).

25. Can an individual bring legal action against a polluter, owner or occupier?
An individual can bring a claim for damages, including compensation for:
• Damage to their property.
• Harm to their health.
• Mental and emotional suffering.
Further, an individual may bring a claim for compensation of harm caused to the environment, irrespective of
whether harm was caused to their health or property. However, such claims are difficult to prove, as they require
detailed technical/environmental evidence, and consequently they are rarely seen in practice.
Environmental liability and asset/share transfers
26. In what circumstances can a buyer inherit pre-acquisition environmental liability in an asset sale/
the sale of a company (share sale)?
Share sales are most common in Russia for real estate acquisition projects, whether the target is an existing business
or a new development. Asset deals are used less frequently and may be chosen for sales of distressed assets or in
other circumstances where a share deal is less preferable due to commercial reasons.
Asset sale
Under an asset sale, the buyer acquires only the assets themselves, and any pre-acquisition liabilities remain with
the seller. Accordingly, in case of an asset sale, environmental liability for losses/damage to third parties caused
prior to the sale will remain with the seller.
Share sale
Under a share sale, the buyer acquires the target company together with all its assets and liabilities. Therefore, all
risks and liability associated with the target company are inherited by the buyer.

27. In what circumstances can a seller retain environmental liability after an asset sale/a share sale?
Asset sale
The seller can retain environmental liability after an asset sale if the loss/damage to the environment was caused
by the seller.
Share sale
In the case of a share sale, the seller may retain contractual liability to the buyer if the sale and purchase contract
includes environmental representations and warranties in relation to the company and/or its assets. In the case of
environmental liability of the company, the seller can potentially be held liable for losses or damage caused by it due
to breach of those environmental representations and warranties and/or by way of indemnity (that is, the seller may
be liable to pay compensation for losses associated with the environmental liability borne by the company).
28. Does a seller have to disclose environmental information to the buyer in an asset sale/a share sale?
Share sale
There is no statutory requirement for sellers to disclose environmental information to buyers under a share sale or
an asset sale.
A diligent buyer would undertake legal and technical due diligence covering a range of issues, including
environmental matters, to identify any potential risks and liability connected with the target company, including
both its business and assets.
If the sale and purchase contract includes environmental representations and warranties, the seller may be held
liable for losses due to misrepresentation and/or breach of those representations or warranties.
Russian law also provides that a buyer who was not aware of defects in goods (including defects identified in a
company and/or its assets after purchase) is entitled to compensation for the cost of rectifying the defects and/or can
claim a proportional reduction of the purchase price. If the defects prove to be substantial, the buyer, at its discretion,
may elect to terminate the sale and purchase contract. Therefore, if a buyer proves that breach of environmental
representations and warranties caused losses and damage to the buyer, the buyer can claim:
• Rectification of defects (if possible).

• Proportionate reduction of the purchase price.
• Termination and rescission of the sale and purchase contract.
29. Is environmental due diligence common in an asset sale/a share sale?
Scope
Whether environmental due diligence is conducted or not largely depends on the type of assets or business being
acquired. In real estate transactions, particularly those involving future construction work and real estate finance,
it is important to undertake a thorough environmental due diligence exercise. Environmental due diligence is also
commonly conducted in deals on the acquisition of a business that involves hazardous activities and/or the use of
hazardous substances.
Types of assessment
The environmental due diligence for a real estate acquisition project typically includes both legal and technical/
environmental assessment.
Legal assessment includes reviewing key environmental permits and licences, and also liability. Environmental
consultants are typically appointed to:
• Provide an in-depth analysis of the company's activities.
• Identify whether or not the company complies with environmental requirements.
• Perform various monitoring measures.
Environmental consultants
In addition to carrying out environmental due diligence reviews, environmental consultants conduct EIAs, which
are typically triggered in connection with major infrastructure and real estate financing projects (see Question 17).
Engagement letters with environmental consultants should contain provisions on the scope of work and any
limitations in relation to the consultant's liability.

30. Are environmental warranties and indemnities usually given and what issues do they usually
cover in an asset sale/a share sale? Are there usually time limits or financial caps on environmental
warranties and indemnities?
Asset sale
Environmental warranties and indemnities are becoming more common in both asset and share sales.
A seller declaration that the assets being sold comply with the applicable environmental and sanitary requirements
is one of the most common environmental warranties. The most typical indemnity is an obligation to compensate
damage or fines imposed if any environmental or sanitary breaches are detected within a specified time after the
closing of the transaction.
Share sale
Warranties and indemnities used in share sales are similar to those used in asset sales (see above, Asset sale).
Environmental warranties are usually subject to a time limit for claims of between one and three years. This is shorter
than the limitation period typically agreed for claims related to title warranties, which is usually three to five years.
There is usually a liability cap for real estate purchase deals (in either share sale or asset sale form) of between 5%
and 25% of the deal value.
A time limit of up to three years is usually applicable to environmental indemnity claims. No cap typically applies.
Reporting and auditing
31. Do regulators keep public registers of environmental information? What is the procedure for a
third party to search those registers?
Public registers
Aggregated information on various environmental aspects is published annually on the website of the Russian
Ministry of Natural Resources and Ecology (http://www.mnr.gov.ru/docs/gosudarstvennye_doklady/). This
aggregated information does not include specific details of individual polluters (for example, existing facilities, types
and volumes of emissions), but contains general statistical information on Russia's environment.
A register of facilities that have a negative impact on the environment is available online at www.onv.fsrpn.ru.
The purpose of the register is to collect up-to-date information on emissions generated by industrial facilities. The
creation of this register is part of the regulatory reform of the environmental permitting regime (see Question 4 and
Question 5). Information available in the register includes the:

• Registered number and name of the facility.
• Company operating the facility.
• Category assigned to the facility (I to IV) (see Question 4).
• Types and volumes of atmospheric, water and waste emissions.
Third party procedures
The types of information listed above can be obtained online or by written application to the competent authorities.
32. Do companies have to carry out environmental auditing? Do companies have to report information
to the regulators about environmental performance?
Environmental auditing
Environmental auditing is voluntary.
Reporting requirements
As mentioned above, all emitting facilities are classed under Categories I to IV (that is, from highest to minimal
environmental impact) (see Question 4).
Certain reporting requirements are established for companies operating Category I, II and III facilities. In particular:
• Category I facilities must install equipment that will automatically report emission volumes and pollutant
concentrations to the state environmental monitoring database.
• Category I, II and III facilities must run an internal programme for ecological control and report annually on
various environmental factors (including volumes of emissions into the air and/or water and the volumes of
waste).
• Category IV facilities are exempt from reporting obligations.
Changes in process technology which affect the emission volumes and/or changes in abatement equipment should
be notified to the authorities, as they may trigger reclassification of the facility into a different category.

33. Do companies have to report information to the regulators and the public about environmental
incidents (such as water pollution and soil contamination)?
Under Russian law, companies must report information about emergency situations, both naturally occurring and
anthropogenic in character, which have caused or may lead to fatalities, injuries or environmental harm and/or
significant material losses.
34. What powers do environmental regulators have to access a company?
During an on-site inspection officials of Rosprirodnadzor have the right to:
• Obtain information and copies of documents from the company representatives (but not to conduct searches
or to seize original documents).
• Access without hindrance and inspect buildings, land, equipment and materials (but without the use of
force).
• Perform necessary tests or measurements.
35. What obligations are there on companies to report on environmental issues in their annual
corporate reports?
Companies are not obliged to include information on environmental issues in their annual corporate reports.
36. What mandatory GHG, carbon reporting or transparency requirements apply to corporates,
including as part of their annual corporate reporting requirements? Is reporting in accordance with
the Task Force on Climate-related Financial Disclosures (TCFD) recommendations? Do any voluntary
GHG reporting schemes exist?
Mandatory requirements

The system for reporting GHG emissions in Russia is being developed in three stages, commencing in 2015:
• In stage I (2015-2020), a system for monitoring, reporting and verifying the volume of GHG emissions in
Russia will be set up with the involvement of major companies in key sectors.
• In stage II (2021-2024), the system will be implemented in other sectors, taking into account indirect energy
emissions of greenhouse gases.
• In stage III (from 2024 onwards), the reporting obligation will apply to all companies with GHG emissions
of more than 50,000 tonnes of CO2 equivalent per year, as well as to aviation, railway, and maritime and
inland waterway transport.
Voluntary schemes
The Code of corporate governance of the Central Bank of Russia which provides recommendations to listed
companies encourages them to prepare sustainability reports in accordance with international standards such as
Global Reporting Initiative (GRI). For example, from February 2020, the list of companies who have expressed
support for the Task Force on Climate-related Financial Disclosures (TCFD) as published on its official website
included SIBUR LLC and UC Rusal. Another example of a popular voluntary reporting scheme in Russia is the
Carbon Disclosure Project (CDP) which is followed by Gazprom, Evraz, Arkhangelsk Pulp & Paper Mill and others.
37. What corporate governance requirements apply in relation to climate change?
Russian law does not establish mandatory corporate governance requirements applicable in relation to climate
change. However, pursuant to recommendations formulated by the Central Bank of Russia in the Code of corporate
governance for the listed companies, a company's exposure to ecological and other non-financial risks should be
evaluated and managed by its board of directors. In practice, certain companies (for example, RusHydro) have a
specific committee in their board of directors responsible, among other things, for ecological policy-making and
preparation of internal regulations related to environmental protection.
Environmental insurance
38. What types of insurance cover are available for environmental damage or liability, and what risks
are usually covered? How easy is it to obtain environmental insurance and is it common in practice?

Types of insurance and risk
Environmental insurance is common in Russia and covers both naturally occurring and anthropogenic risks.
In particular, owners or operators of "hazardous industrial facilities" (including gas networks, boiler houses, facilities
for the storage of toxic chemicals, and hydraulic engineering facilities) are obliged to obtain insurance covering the
risks of third party liability as a result of an accident at the facility.
In addition, investors under production sharing agreements are obliged to obtain insurance covering the risks of
liability for harm to the environment in case of accidents.
Voluntary environmental insurance is available for risks of third party liability for pollution caused by activities not
covered by mandatory insurance.
Obtaining insurance
An insurance policy can be obtained from a company duly licensed by the Central Bank of Russia as an insurer
of environmental risks. Before taking out a policy, it is advisable to verify the insurer's capacity to issue policies
covering environmental risks.
Environmental taxes
39. What are the main environmental taxes?
The following Russian taxes and levies can be considered environmental taxes.
Water tax
Water tax is payable for the use of water where such use is subject to obtaining a licence. Currently only extraction
of groundwater is licensed. Generally, the amount of water tax depends on the volume of water extracted, the type
of water body and the water basin. For example, the following tax rates apply:
• From RUB693 to RUB1,566 per 1,000 cubic metres of river/lake water extracted.
• From RUB 9.98 to RUB34.37 per 1,000 cubic metres of seawater extracted.
Other types of water usage not requiring a licence may still be subject to charges in the form of payments for water
use under the Russian Water Code. Such payments are not treated as taxes.
Ecological levy

An ecological levy is payable by producers and importers of goods that are subject to recycling. The payers of the
levy can either engage in recycling or pay the levy. However, recently Russian environmental authority declared the
first option (recycling) inefficient and prepared a draft law proposing to:
• Oblige all producers and importers of goods and packaging to pay the ecological levy under the supervision
of tax authorities, which are viewed as more efficient in collecting levies and taxes than the Russian
ecological authorities currently in charge of collecting the levy.
• Use the collected levy to finance activities of specialised entities responsible for recycling.
Currently the rates of the ecological levy for various types of goods are set by the Russian government depending on
the type of goods, their packaging and whether the applicable recycling target has been met.
Utilisation levy
A utilisation levy aimed at "ensuring the environmental safety" of Russia is payable in respect of certain activities
involving motor vehicles and trailers. The levy is payable by:
• Importers or manufacturers of vehicles.
• Purchasers of vehicles, where the levy has not been paid by a previous owner.
• Owners of vehicles that were placed under the "free customs zone" procedure applied in the designated
Special Economic Zone in the Kaliningrad region on the change of the customs procedure (other than re-
export), if no utilisation levy has been previously paid.
The list of vehicles in relation to which the levy is payable and applicable rates are set by the government. The rates
vary depending on the type of vehicle, its horsepower, age, engine capacity, weight and so on.
Tax incentives
Some provisions of Russian tax legislation are also intended to promote environmental protection and energy
efficiency, including:
• An investment tax credit available for taxpayers involved in:
• conducting R&D or modernisation of equipment aiming at enhancing energy efficiency; or
• implementing environmental protection measures.
(Russian Tax Code, Article 67.)
• Accelerated depreciation for energy-efficient fixed assets (Russian Tax Code, Article 259.3).
• Exemption from property tax for energy-efficient fixed assets (Russian Tax Code, Article 381).
• Reduced transportation tax rates, depending on the environmental class of vehicles (Article 361, Russian
Tax Code).

• Exemption from transportation tax set at regional level. For example, in Irkutsk region, an exemption is
available in relation to a fully electrical personal car which charges using an external source.
Tax liability
See above.
Tax rates
See above.
Reform
40. Are there any proposals for significant reform of environmental law?
In addition to the major reform of 2014 to 2018 introducing the integrated environmental permitting regime (see
Question 4 to 8), the Russian government is working on several other regulatory changes, including a new legal
framework for limiting GHG emissions.
The key proposals under the draft law are:
• GHG emissions will be limited, and the applicable limit will vary depending on the industry sector.
• Entities whose business leads to direct emissions of GHG will need to obtain a separate permit.
• Entities exceeding the emission limits set out in the special permit will be subject to special levies.
If ultimately enacted, the new regulatory framework will be rolled out gradually up to 1 January 2025.
A major reform related to handling municipal solid waste started in 1 January 2019, which requires, in particular,
that:
• The full cycle of activities related to collection and disposal of waste will be handled by specialised operators
to be selected on a competitive basis in each region.
• Waste management programmes must be approved at the regional level.
• Stricter control will apply over the waste disposal to eliminate illegal waste dumping.
• Separate waste collection will be promoted.

• The system of payments for waste disposal will be revised, which is expected to result in an increase of
financial burden on households and companies.
The "waste reform" started on 1 January 2019. However, a special transitional period was introduced for the cities
of federal significance (Moscow, St. Petersburg and Sevastopol) until 1 January 2022. Further, implementation of
the reform remains conditional upon enactment of various regulations at the regional level. In particular, regions
were entitled to postpone implementation of the reform until 1 January 2020 where the process for selection of an
operator failed. Given the limited progress on the selection of operators and approval of necessary regulations in
some regions over the past year, it remains possible that the deadlines will be postponed further.
Contributor profiles
Marc Bartholomy, Partner, Head of Corporate and Real Estate practices
Clifford Chance
T +7 495 660 80 06
F +7 495 258 50 51
E marc.bartholomy@cliffordchance.com
W www.cliffordchance.com
Professional qualifications. University of Cologne, Germany
Areas of practice. Real estate; environmental law; construction and development; financing; leasing;
corporate; joint ventures; M&A and asset disposals.
Recent transactions
• Advising a Russian platform established by a consortium of sovereign wealth investors for

the acquisition and operation of a diversified logistics portfolio in Russia, on the proposed
acquisition of an A-class warehouse complex with a total area of about 100,000 square
metres, consisting of several buildings together with the underlying land plots and associated
infrastructure.
• Advising Vi Holding on its USD1.5 billion joint venture with RDIF and other sovereign wealth
funds from China and the Middle East, including RCIF, the Silk Road Fund and Mubadala, to
develop the Tushino Waterfront Mixed-Use Development. Vi Holding holds the development
rights for the project, a landmark development and construction project of about 1 million square
metres.
• Advising Fortum, a subsidiary of a Fortum Oyj, a European energy corporation, in connection

with construction of a wind farm with a capacity of 35 MW in the Ulyanovsk region, Russia,
including advising on environmental requirements applicable to the project.
Languages. German, English, Russian

Ella Omelchenko, Counsel, Corporate Real Estate, Head of Construction

Practice
Clifford Chance
T +7 495 258 5054
F +7 495 258 5051
E ella.omelchenko@cliffordchance.com
Professional qualifications. Lawyer (Russian law)
Areas of practice. Real estate; environmental law; renewable energy; construction and development;
PPP.
Recent transactions
• Advising one of the leading metallurgical companies in Russia in connection with the
construction of sulphur production facilities at its metallurgical plant and copper plant located
in Krasnoyarsk region, Russia. The project is claimed to be the company's most ambitious
environmental initiative aimed at radically improving the environment in its regions of
operations.
• Advising the project company in a new liquefied natural gas project near the Gydan Peninsula
in north-western Siberia. The project involves the construction of three LNG trains, each with a
capacity of 6.6 million tonnes per year, using gravity-based structures (GBS). Advice included all
Russian law construction matters, including regulatory, licensing and permitting matters, land
and procurement issues.
• Advising a major Russian mining company on its expansion and modernisation project for
development of the Udokan copper deposit.
• Advising on construction and operation of water supply and disposal systems on a PPP basis,
including the concession agreement and the direct agreement with the banks.
• Advising one of the largest Russian airports on noise regulation in Russia and overview of
European noise regulation, including preparation of an overview with initiatives on amendments
of the Russian noise regulation.
Languages. Russian, English
Publications
• "Public-Private Partnerships. Comments on the Federal Law on Public-Private Partnerships

and Municipal-Private Partnerships in the Russian Federation" (2016) (co-author).
• "Public-Private Partnerships. Main principles of financing" (2015) (co-author).

Dmitrii Tolkachev, Senior Associate, Tax practice
Clifford Chance
T +44 (0)20 7006 5553
F +44 (0)20 7006 5555
E dmitrii.tolkachev@cliffordchance.com
Professional qualifications. Lawyer (Country qualified: Russia), PhD in law
Areas of practice. Tax aspects of finance; capital markets; M&A; customs; exchange control; tax
dispute resolution.
Recent transactions
• Advising Microsoft Mobile Russia on the applicability of new environmental levies to waste
disposal procedures.
• Advising Vi Holding on its USD 1.5 billion joint venture with RDIF and other sovereign wealth
funds from China and the Middle East, including RCIF, the Silk Road Fund and Mubadala, to
develop the Tushino Waterfront Mixed-Use Development. Vi Holding holds the development
rights for the project, a landmark development and construction project of about 1 million square
metres.
• Advising Remington Holding International LLC, leading provider of customised seed production,
processing, logistics and related services to the global seed industry, on various legal matters in
connection with construction and operation of a seed processing plant in one of Russia's southern
agricultural regions.
Professional associations/memberships. Member of the International Fiscal Association (IFA);

member of the Taxation Committee of the Association of European Businesses (AEB); member of the
Taxation Committee of the American Chamber of Commerce in Russia (AmCham); member of the
Aviation Working Group (AWG).
Publications. "Russian GAAR: Carrot, Stick or Both?" in CEE Legal Matters magazine (November
2017).
Maria Chivragova, Lawyer, Corporate Practice
Clifford Chance
T +74956608077
F +74952585051
E maria.chivragova@cliffordchance.com

Professional qualifications. Lawyer (Russian law)
Areas of practice. Regulatory matters.
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Environmental law and practice in the Russian Federation:..., Practical Law Country...

Environmental law and practice in the Russian

Country Q&A | Law stated as at 01-Jun-2020 | Russian Federation

A Q&A guide to environmental law in Russia.

Environmental regulatory framework

Codes and federal laws cover matters such as:

• Environmental protection, including environmental expert assessment and so on.

• Sanitation and epidemiology.

• Activities on the continental shelf and in the territorial sea.

© 2021 Thomson Reuters. All rights reserved. 1

• Sanitary and hygiene standards and requirements (SANPIN).

• Hygienic norms (GN).

• Construction rules (SP).

• Construction norms and rules (SNIP).

• State standards (GOST).

• Federal Service for Supervision of Natural Resource Usage (Rosprirodnadzor).

• Federal Agency for Water Resources (Rosvodresursy).

• Federal Forestry Agency (Rosleskhoz).

• Federal Agency for Subsoil Use (Rosnedra).

• Federal Service for Hydrometeorology and Environmental Monitoring (Rosgidromet).

2. To what extent do regulators enforce environmental requirements?

© 2021 Thomson Reuters. All rights reserved. 2

© 2021 Thomson Reuters. All rights reserved. 3

• Simplification/abolition of permitting procedures for other categories of emitting facilities.

5. What is the framework for the environmental permitting regime?

© 2021 Thomson Reuters. All rights reserved. 4

Permits and regulator

Water pollution and abstraction

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Discharges into the environment

Discharge into central sewage systems

Permits and regulator

It is generally prohibited to:

• Discharge wastewater into the environment without a permit.

• Discharge prohibited substances with waste water.

• Exceed any prescribed emission limits.

© 2021 Thomson Reuters. All rights reserved. 6

Permits and regulator

A licence is not required if the:

The extraction of groundwater for commercial needs without a licence is prohibited.

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Permits and regulator

It is generally prohibited to:

• Release any prohibited substances into the air.

• Exceed any prescribed emission limits.

Penalties for air pollution include civil, administrative or criminal penalties.

© 2021 Thomson Reuters. All rights reserved. 8

Plan for reduction of greenhouse gas emissions

© 2021 Thomson Reuters. All rights reserved. 9

To reach this goal, the government has:

11. Do any emissions/carbon trading schemes operate?

There are two main schemes for carbon trading:

• Carbon trading under Article 6 of the Kyoto Protocol.

• The voluntary carbon market.

Article 6 of the Kyoto Protocol

• Implementation of the project.

• Transfer of the emission reduction units.

© 2021 Thomson Reuters. All rights reserved. 10

Voluntary carbon market

Energy strategy to 2030

© 2021 Thomson Reuters. All rights reserved. 11

13. Do any renewables support schemes operate?

• Pricing stimuli for enhanced use of renewable energy.