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Review of the joint informational Letter of the Ministry of natural resources and environment of the Russian Federation and Rosprirodnadzor on licensing of activities on waste management


The Ministry of natural resources and environment of the Russian Federation in the Letter dated 13.04.2017 No. АС-10-01-36/7619 (hereinafter – the “Letter”) clarifies a number of issues concerning licensing of activities on management of wastes included in I - IV hazard classes.

The key conclusions of the Ministry of natural resources and environment of the Russian Federation are outlined below:

  • Waste collection is the initial stage of waste management and is aimed at securing any of the subsequent methods of waste management. In this regard, waste reception or arrival from individuals and legal entities for subsequent implementation in relation to such waste of at least one of the waste management activities (treatment, recycling, neutralization, transportation and disposal) is considered to be collection of waste.
  • Collection of waste is implemented only within special sites. Such sites are specific territories, equipped in accordance with the requirements of the Federal law dated 30.12.2009 No. 384-FZ “On technical regulations regarding safety of buildings and constructions” in relation to constructions (clause 23 art. 2). The requirements to constructions, which are used to perform waste collection, are stipulated in sanitary rules (clause 2 art. 40 of the Federal law dated 30.03.1999 No. 52-FZ “On sanitary and epidemiological welfare of the population”), the Federal law dated 10.01.2002 No. 7-FZ “On environmental protection” (clause 1, art. 39, clause 1, art. 51) and technical regulations (the Federal law dated 27.12.2002 No. 184-FZ “On technical regulation”).
  • Collection of waste from a legal entity or individual entrepreneur, whose economic or other activities have resulted in formation of waste, for further neutralization and disposal can be carried out in the same buildings, structures, constructions and premises, where their neutralization and disposal are done. The Ministry of natural resources and environment of the Russian Federation came to the similar conclusion regarding treatment and recycling of waste, i.e. waste collection can be carried out using same equipment and specialized facilities, in which further treatment and recycling of waste is implemented.
  • Requirements to the equipment (including specialized one) and installations required for performing the stated works on treatment of waste, its recycling, neutralization are envisaged by technical regulations ((the Federal law dated 27.12.2002 No. 184-FZ “On technical regulation”).

Hence, the Letter clarifies the process of waste management and emphasizes the phase by phase nature of the activity as well as independent legal and practical meaning of each stage of waste management.



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