Drawing up reporting forms 2-TP
September 13, 2022
Drawing up reporting forms 2-TP Drawing up annual environmental reporting in form 2-TP must be carried out by all legal entities and individual entrepreneurs whose enterprises are sources of pollution of the atmosphere, soil and water bodies, as well as organizations whose activities are related to the collection, disposal, transportation, storage , transfer to other entities of consumption/production waste (construction waste, oil waste, etc.). The report is prepared separately for the following […]
Fine for violating the deadline for submitting Form 4-OS
- for officials ranges from 3,000 to 5,000 rubles (for repeated violations: 30,000 to 50,000 rubles).
- for legal entities and enterprises - from 20,000 to 70,000 rubles (for repeated violations: 100,000 - 150,000 rubles).
The environmental fee is paid by facilities that produce or import goods and packaging that are subject to mandatory recycling. The fee is not paid only if the organization disposes of the goods or their packaging independently (and in full). Ecological collection is monitored by Rosprirodnadzor. The environmental fee must be paid by April 15 of the following year.
Drawing up an environmental action plan and a summary report on environmental actions
September 13, 2022
Drawing up a plan of environmental measures and a summary report on environmental measures Drawing up a plan of environmental measures and a summary report on environmental measures is carried out by legal entities and individual entrepreneurs owning production facilities of hazard categories II and III, if it is impossible to comply with the standards for permissible emissions and discharges of pollutants. In a similar situation, at factories with hazard class I facilities, a program is being developed to increase […]
Fine for non-payment of environmental fee
- for an official – from 5,000 to 7,000 rubles,
- for a legal entity - three times the amount of the unpaid amount, but not less than 250,000 rubles,
- for an enterprise – three times the amount of the environmental fee, but not less than 500,000 rubles.
Fees for NVOS (negative environmental impact) are paid by all natural resource users. This is a form of monetary compensation, in fact, a fiscal fee. Today, according to the legislation of the Russian Federation, fees are charged for air pollution, discharge of harmful substances into water, and waste dumping. The report on the compensation paid, just like the environmental fee, is submitted to Rosprirodnadzor. Large enterprises pay the fee four times a year - three times before the 20th day of the 1st-3rd quarter, and no later than March 1st, the fourth, final payment. Small and medium-sized facilities are exempt from quarterly payments and make only the final payment.
Preparation and entry of information into the consolidated waste inventory
September 13, 2022
Preparation and entry of information into the Consolidated Cadastre of Wastes Preparation of information on production and consumption waste, in order to enter and register them in the Consolidated Cadastre, is the responsibility of enterprises operating in Moscow and the regions, as well as individual entrepreneurs who carry out economic or production activities without the formation of a legal entity. faces. This data must be provided: for enterprises in the capital - [...]
Environmental reporting in 2022: Information for all NEI categories
All objects of negative impact on the environment are divided into 4 main categories. Environmentalists and enterprises have long since moved to a new system of environmental control. Each enterprise operating within the framework of environmental legislation knows its own NVOS category.
In any case, it’s never too late to find out your category and register. What changes in environmental legislation does environmental reporting prepare for us in 2022? In the material before you, we will try to list all the requirements for objects of the most dangerous 1st category of NVOS.
Main changes and requirements for all NVOS facilities
I would like to start with annual reporting forms. The requirements listed below remain the same even for so-called “uncategorized objects”.
Waste passports
The rules for certification of waste of hazard classes 1-4 are approved by Decree of the Government of the Russian Federation dated August 16, 2013 No. 712. All waste passports are valid indefinitely. Rosprirodnadzor is responsible for their approval.
Report form 2-TP (waste)
By Order of Rosstat dated 10/09/2020 No. 627 (as amended on 11/13/2020) “On approval of the federal statistical observation form with instructions for filling it out for the organization of federal statistical observation of production and consumption waste by the Federal Service for Supervision of Natural Resources”, changes were made to the form 2-TP (waste). Consequently, order No. 766 lost its force. We remind you that users of natural resources must submit Form 2-TP (waste) to the territorial body of Rosprirodnadzor no later than February 1, 2022!
The ability to enter information on the annual federal statistical observation form 2-TP (waste) will be available for trial operation in the updated version of the Natural Resources User’s Personal Account (lk.rpn.gov.ru), starting from 12/15/2020. In order to explain the procedure for filling out form 2-TP (waste) and answers to the most frequently asked questions, a Memo for the user of natural resources on filling out form 2-TP (waste) has been prepared at the link https://rpn.gov.ru/upload/iblock/480/2_5372835325146040514 %20(2)_copy.pdf
Report form 2-TP (vodkhoz)
Reporting for water users who discharge harmful pollutants into water bodies. The 2-TP (vodkhoz) form was amended by Rosstat Order No. 118 dated March 12, 2022 “On amendments to the federal statistical observation form No. 2-TP (vodkhoz) “Information on water use”, approved by Rosstat order dated December 27, 2022 No. 815". The changes take effect from the date of reporting for 2022. The deadline for submitting the 2-TP (vodkhoz) report to the territorial bodies of Rosvodresursov is January 22, 2022!
Environmental fee
Eco-collection is a prerequisite for compliance with environmental regulations for disposal. Payment of the environmental fee is due April 1. The report must be submitted by April 15. First of all, the environmental fee allows manufacturers to legally dispose of packaging and other materials.
Emissions inventory
According to Article 32 of Order No. 352 of the Russian Ministry of Natural Resources dated August 7, 2018, every enterprise must have an inventory report on emission sources (as a separate document). Based on the results of the emissions inventory, a report is drawn up containing inventory data and approved by the business entity carrying out economic or other activities at the NDC facility, indicating the date of approval. A recommended sample structure of an emission inventory report is given in Appendix No. 4 to Order No. 352.
Which documents will be canceled in 2022?
By Decree of the Government of Russia of September 18, 2022 No. 1496, the following legislative documents are repealed from January 1, 2022:
1. Order of the Ministry of Natural Resources and Ecology of the Russian Federation dated July 8, 2009 No. 205 “On approval of the Procedure for maintaining by owners of water bodies and water users the volume of withdrawal (withdrawal) of water resources from water bodies and the volume of discharge of wastewater and (or) drainage water , their qualities.” By Decree No. 1496, this document will be canceled starting January 1, 2022. It follows that in 2022, information in forms No. 3.1, 3.2, 3.3 and 6.1, 6.2, 6.3 is not required. At the moment, we can only assume that water accounting at the facility will be carried out using other forms until new documents are adopted.
2. Decree No. 1496, from January 1, 2022, also canceled waste movement logs in accordance with Order of the Ministry of Natural Resources of Russia dated September 1, 2011 No. 721.
3. As of January 1, 2022, the guidelines for the development of draft standards for waste and discharges have also been canceled.
Additional information about current changes: environmental reporting in 2022
Decree of the Government of the Russian Federation dated November 30, 2020 No. 1969 “On the specifics of the formation of annual plans for conducting scheduled inspections of legal entities and individual entrepreneurs for 2021, conducting inspections in 2022 and amending paragraph 7 of the Rules for preparation by state control (supervision) bodies and municipal authorities has been published control of annual plans for conducting routine inspections of legal entities and individual entrepreneurs.”
We recommend that you familiarize yourself with Resolution No. 1969 (Resolution of the Government of the Russian Federation of November 30, 2020 N 1969 “On the peculiarities of the formation of annual plans for conducting scheduled inspections of legal entities and individual entrepreneurs for 2022, conducting inspections in 2021 and amending paragraph 7 of the Rules for preparation by state control bodies (supervision) and municipal control bodies of annual plans for conducting scheduled inspections of legal entities and individual entrepreneurs") to each business entity who is subject to state and municipal control.
Main innovations according to Decree No. 1969
§ Introduction of a remote format of inspections via audio or video communication, in addition to face-to-face inspections;
§ Starting from July 1, 2022, the state control body may conduct an inspection visit instead of a scheduled inspection;
§ From June 30, 2022, the period for conducting scheduled inspections will be reduced to 10 days. A scheduled inspection is canceled if it must be carried out in accordance with ineffective or amended norms of the legislation of the Russian Federation;
§ The annual inspection plans do not include small businesses except those entities specified in paragraph 8 of Decree No. 1969;
§ In clause 7 of the Rules for the preparation by state control (supervision) bodies and municipal control bodies of annual plans for conducting scheduled inspections of legal entities and individual entrepreneurs, approved by Decree of the Government of the Russian Federation of June 30, 2010 No. 489, additional cases are introduced in which adjustments to inspection plans are possible.
Legal requirements for objects of category 1
§ KER;
§ Waste generation standards within the framework of the IEP;
§ PEC program;
§ Development of standards for permissible emissions, discharges, technological standards;
§ Development of a program to improve environmental efficiency;
§ Obtaining permission for harmful physical effects on atmospheric air;
§ Tax payment;
§ Report on PEC;
§ Report form 2-TP (air);
§ Report form No. 4-OS;
§ Report form No. 2-OS;
§ Development of activities for NMU.
Now you know what changes environmental reporting is preparing for us in 2022.
From year to year, environmentalists and enterprises try to keep up with changes.
#Ecology AR
Report on industrial environmental control (PEC)
September 13, 2022
Report on industrial environmental control (PEC) A report on industrial environmental control is required to be submitted annually by March 25 to all enterprises and individual entrepreneurs without forming a legal entity that operate in Russia. Reporting on PEC is provided by organizations: those with objects of class I (category) of danger - to the federal authorities involved in supervision in the field of environmental management; having objects II and […]
Fine for violating the deadline for submitting Form 2-TP
- for officials ranges from 3,000 to 5,000 rubles (for repeated violations: 30,000 to 50,000 rubles).
- for legal entities and enterprises - from 20,000 to 70,000 rubles (for repeated violations: 100,000 - 150,000 rubles).
The 4-OS report is required to be provided by all organizations whose environmental costs exceed 100,000 rubles per year. Such a report includes data on environmental protection costs and environmental payments. The form is submitted to the territorial bodies of Rosstat at the place of actual activity of the enterprise, the deadline for submission is January 25 of the year following the reporting one.
Where and how to report
The environmental reporting listed above is submitted:
- manufacturers - to the territorial RPN authority at their location;
- importers - to the central office of the RPN (Moscow).
Companies or individual entrepreneurs that are both manufacturers and importers also report to the central office of the RPN (Moscow). As a rule, reporting is submitted via the Internet. However, if you do not have the technical ability to connect to the Internet, you can submit it on paper by attaching a flash drive or disk with an electronic version of the report in xml format.
Risk-free reporting
In most cases, environmentalists are concerned about how to ensure the legal significance and security of data that is transmitted to the regulatory authority via TCS.
Legal significance
Each generated report is signed with an electronic signature certificate before being sent to Rosprirodnadzor from the electronic service via TCS. According to the Federal Law of 04/06/2011 No. 63-FZ “On Electronic Signatures” (as amended on 06/23/2016), a document signed with an electronic signature is recognized as equivalent to a paper one, which is signed with one’s own hand and certified by a seal. In other words, a document with an electronic signature has the same legal force as its paper counterpart.
It is thanks to the electronic signature that legally significant electronic document flow within companies and with external contractors, as well as receiving services on government portals (for example, gosuslugi.ru), became possible.
Safety
An electronic signature protects an electronic document from forgery, allows you to identify the owner of the signature key certificate, and also establish the absence of distortion of information in the electronic document.
note
The electronic signature must be obtained from a certification center (hereinafter referred to as the CA) accredited by the Ministry of Telecom and Mass Communications of the Russian Federation. CAs play an important role in the process of submitting electronic reporting - they confirm the authenticity of information about the owner of the electronic signature and his powers. In order to issue an electronic signature, you need to submit a number of documents to the CA that prove your identity and authority.
Very often telecom operators have their own CAs. This is convenient for users, because... they can connect to the reporting system and receive an electronic signature to work with it in one place.
Reliability of telecom operators
Many resource users are afraid to switch to submitting reports using TCS because they do not trust the telecom operator. When an ecologist does not communicate directly with a Rosprirodnadzor inspector, he has no confidence that his report has been received.
Here it is worth turning to the example of other regulatory authorities that have extensive experience working with telecom operators. 15 years ago, the Federal Tax Service of Russia began transferring taxpayers to electronic reporting, and now over 90% of all organizations in Russia submit reports to the tax authorities through the electronic systems of various operators[3].
Telecom operators accredited according to legal requirements guarantee the delivery of reports to regulatory authorities. When choosing a telecom operator, we recommend paying attention to the following points:
• how long the operator has been on the market and with which regulatory authorities it cooperates;
• does the operator have the resources to regularly configure and refine the reporting system in the context of rapidly changing legislation;
• in which cities the operator is represented;
• how the operator's technical support service works.
