SME reporting - small and medium-sized businesses are required to maintain a Report on the generation, use, disposal and disposal of waste

1. Waste reporting for SMEs
2. Technical report on waste management
3. Form 2-TP (air)
4. Form 4 – OS (current costs)
5. Form 2-TP (waste)
6. Declaration of payment for negative environmental impact
7. Report on the PEC program

We lived for a whole year under the new system of environmental control and supervision.
Now enterprises already know which hazard category the objects of negative impact they own belong to and what documents must be developed. Many have already carried out industrial environmental control during the year according to the new rules. At the end of December, the country's first comprehensive environmental permit for a category I facility was solemnly issued. In 2021, enterprises reported under the new rules for the first time. Here is material about how the environmental reporting campaign 2021 took place. You can find the latest material for 2021 by clicking the button below!

Environmental reporting 2021

Waste reporting for SMEs in 2020

9 years have already passed since this reporting was introduced for small and medium-sized businesses. It was submitted annually by January 15 and was called “Report on the generation, use, disposal and disposal of waste by small and medium-sized businesses.” The procedure and form for submitting a report for SMEs operating NDC facilities related to the federal level of environmental supervision in accordance with Resolution No. 903 of 08/28/15 was regulated by Order of the Ministry of Natural Resources of the Russian Federation dated 02/16/2010 N 30. For facilities at the regional level of supervision, forms and the order was established by local authorities. After the changes came into force last year, it was not clear whether it was necessary to submit these reports for 2021. Let’s look at the requirements of the law:

Federal Law dated June 24, 1998 N 89-FZ (as amended on August 2, 2019) “On production and consumption waste”

Article 18. Standardization in the field of waste management

[…]

3. For legal entities or individual entrepreneurs carrying out economic and (or) other activities at category I facilities, determined in accordance with legislation in the field of environmental protection, waste generation standards and limits on their disposal are established on the basis of a comprehensive environmental permit provided for by law in the field of environmental protection.

4. Legal entities and individual entrepreneurs carrying out economic and (or) other activities at objects of category II, defined in accordance with legislation in the field of environmental protection, include information on the volume or mass of waste generated and disposed of in the environmental impact declaration in accordance with environmental legislation.

5. Legal entities and individual entrepreneurs carrying out economic and (or) other activities at objects of category III, determined in accordance with legislation in the field of environmental protection, submit to the federal executive body authorized by the Government of the Russian Federation or the executive bodies of state power of the constituent entities of the Russian Federation in accordance with their competence, in a notification procedure, reporting on the generation, use, neutralization, and disposal of waste.

6. When carrying out economic and (or) other activities at objects of IV category, determined in accordance with legislation in the field of environmental protection, the development of waste generation standards and limits on their disposal and reporting on the generation, use, neutralization, and disposal of waste is not required.

[…]

These provisions came into force on January 1, 2021. Before this period, Article 18 stated that small and medium-sized businesses that generate waste must submit reports on the generation, disposal, neutralization and disposal of waste. Last year, the majority of SMEs submitted these reports. At the same time, the reporting form that enterprises operating category III facilities must submit, and which is specified in the law, was not established during 2019. In addition, according to the provisions of Federal Law No. 219-FZ, enterprises operating category III facilities will have to submit similar reports in the area of ​​impact on atmospheric air, the form of which has also not been established today.

At the end of 2021, several enterprises sought clarification from authorized authorities regarding the need to submit reports for SMEs. The answers, as always, are vague. One of the responses to a request to the Ministry of Natural Resources of the Moscow Region nevertheless explained that the division into SMEs when considering waste management issues is no longer used; only the division depending on the category of NDC objects is applicable. In accordance with this, reporting of this kind should only be provided by enterprises operating category III NVD facilities. Thus, all other categories are exempt from this reporting, and for category III its form is not established. Most likely, reports will be accepted in the forms and in the order in which SME reports were accepted.

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Environmental reports from 2021 Order a service

From 2021, new environmental reporting rules will be introduced. All enterprises will be divided according to the degree of environmental hazard and reporting will be generated depending on this category. The table below presents environmental documentation and the type of reporting that is required for all categories of enterprises.

Technical report on waste management in 2021

Until January 1, 2021, it was mandatory for large business enterprises with PNOOLR to pass it. The NOLR project operated for 5 years, subject to annual submission of a report . For facilities with a federal level of supervision, the project and technical report were developed in accordance with Order of the Ministry of Natural Resources of Russia dated 05.08.2014 N 349 “On approval of Guidelines for the development of draft standards for waste generation and limits on their disposal”, for “regionals” - in accordance with regional guidelines and procedures in force in accordance with the established procedure. In case of untimely submission of a technical report to the authorized body, the enterprise faced punishment under Article 8.2 of the Code of Administrative Offenses of the Russian Federation. Once 2019 arrived, conditions changed. Thus, standards and limits for the generation and disposal of waste are now only received by enterprises that have category I facilities as part of obtaining a comprehensive environmental permit

Permits for the emission of pollutants into the atmospheric air, limits for emissions of pollutants, discharge permits, discharge limits, standards for waste generation and limits for their disposal, obtained by legal entities and individual entrepreneurs carrying out economic and (or) other activities at NDC facilities, related to objects of categories I and II, until January 1, 2021, are valid until the day of expiration of such permits and documents or until the day of receipt of the IEP or submission of a DOVOS during the validity period of such permits and documents (in accordance with the Federal Law of December 25, 2018 N 496-FZ). From January 1, 2021 until the receipt of the IER, it is possible to issue or re-issue permits and documents that will be valid until the day the IER is received. For objects of category II, it is necessary to submit a DEVOS no later than the day of expiration of at least one of the specified permits and documents. In mid-2021, new changes were made (Federal Law dated July 26, 2019 N 195-FZ), according to which legal entities and individual entrepreneurs operating at category I facilities included in the list of 300 pilot facilities are required to apply for an IEP in period from January 1, 2019 to December 31, 2022 inclusive. Facilities not included in this list must submit an application and receive an IEP before January 1, 2025. Before this period, in accordance with the still valid PNOOLR for these objects, it is necessary to submit technical reports according to established procedures.

If an object belongs to category III, it needs to submit a report on the generation, use, neutralization, and disposal of waste. Since the report form has not yet been adopted, the question remains open. At the same time, the order of the Ministry of Natural Resources of Russia dated February 25, 2010 No. 50 “On the Procedure for the development and approval of waste generation standards and limits on their disposal” for NDC facilities at the federal level of supervision is still in force, as well as local regulations for regional facilities, and, if necessary, or if you wish, a technical report can be submitted “just in case”. In the practice of the author of the article in 2021, such reports were accepted, since the authorized body could not refuse to accept it.

If the NDC object belongs to category IV, the PNOLR is no longer valid for it; accordingly, a technical report does not need to be submitted as part of environmental reporting 2021.

Form 2-TP (air) as part of environmental reporting 2021

Statistical reporting on atmospheric air protection - form 2-TP (air) is submitted to Rosprirodnadzor before January 22 of the year following the reporting year. Order of Rosstat dated November 8, 2018 N 661 “On approval of statistical tools for the organization of federal statistical monitoring of atmospheric air protection by the Federal Service for Supervision of Natural Resources” approved a new form of this reporting. Persons required to submit reports are persons with stationary emission sources whose volumes of permitted emissions of pollutants under the NDC exceed 10 tons per year or 5 to 10 tons per year inclusive if the emissions contain substances of hazard class 1 and (or) 2. If the NVGs operated by a legal entity or individual entrepreneur are located on the territory of different constituent entities of the Russian Federation, then the report in the form is provided separately for each subject. This year there have been no changes in the procedure for filing these reports.

Composition of reporting for SMEs

Small and medium-sized enterprises prepare and submit reports in accordance with the chosen taxation regime.

Mandatory reporting

Declarations according to OSNO

• VAT (KND 1151001) quarterly, until the 28th day of the month following the reporting quarter;
• for profit (KND 1151006) - until April 25, July, October and January of the next year (for the final declaration);
• for property tax (KND 1152026 - each time until March 30 for the previous year;
• income of individuals (KND 1151020 for individual entrepreneurs) - once a year.

USN. Tax return under the simplified tax system KND 1152017 - once a year: legal entity until April 2, individual entrepreneur until May 3 for the previous year.

UTII. Declaration on the imputation of KND 1152016 - every quarter: until April 20, July 20, October 20 and until January 22 for the previous year.

Unified Agricultural Sciences. Tax return KND 1151059 - annually until April 2 for the previous year.

OSNO payers who do not have taxable objects submit a single simplified declaration quarterly.

Specific declarations

Filled out and submitted subject to the organization's ownership of the taxable object and its use in its activities.

• For transport tax KND 1152004 - once a year until February 1;
• For land tax KND 1153005 - once a year until February 1;
• For water tax KND 1151072 - every quarter.

Other tax reporting of MP

For legal entities and individual entrepreneurs with employees:

• Calculation of 6-NDFL - quarterly;
• Form 2-NDFL - annually;
• Information on the average number of staff of KND 1110018 - once a year;
• ERSV - for each quarter;

Our services are aimed at those who strive to work efficiently, without fines and unnecessary attention from tax authorities.

Form 4 – OS (current costs) 2020 model

A new order was issued in 2021 based on the form of this reporting. Order of Rosstat dated July 18, 2019 N 412 (as amended on October 17, 2019) “On approval of federal statistical observation forms for organizing federal statistical observation of agriculture and the natural environment.” Federal statistical observation form N 4-OS “Information on current costs of environmental protection” is provided by legal entities and individual entrepreneurs who have fixed assets for environmental protection purposes, carry out environmental protection measures, and have facilities that have a negative impact on the environment.

Information is provided if there are current costs for environmental protection and (or) payment for environmental services in excess of 100 thousand rubles per year. Reports are still submitted to Rosstat until January 25 of the year following the reporting year.

Where to submit the SME report in 2021

The report discloses waste accounting data: the amount of waste generated and transferred/accepted for storage or neutralization. Information is submitted to regulatory authorities at the end of the reporting year. The information is reflected in accordance with the primary accounting data of the individual entrepreneur or enterprise. The SME form is submitted by those business entities that meet the criteria for being classified as small and medium-sized businesses; the category of reporting entities also includes micro-enterprises.

The SME report in 2021 is submitted to the territorial bodies of Rosprirodnadzor.

The deadline for submitting the report is no later than January 15 of the year following the reporting year. In 2021, when entrepreneurs and companies submit reports based on the results of 2021, the deadline for submission will be 01/15/2020; there are no plans to postpone the deadline.

Depending on the level of subordination of the facilities where waste is generated or disposed, the deadlines for submitting the SME form in the regions may differ. For regional objects, it is necessary to report to the departments of natural resources of the corresponding constituent entity of the Russian Federation, and within the time limits specified in the legal acts of the relevant regions.

Form 2-TP (waste) sample 2020

One of the most stable types of reporting as a subject of environmental reporting 2021 this year also did not escape changes. Moreover, the form of the order changed twice in a year. That is, the first changes occurred with the release of the order by Rosstat Order No. 459 dated August 19, 2019, and 4 months later the new Rosstat Order No. 766 dated December 12, 2019. Thus, according to Order No. 459, not even one report, which clearly shows us the pace of change in environmental legislation.

The new form 2-TP (waste) comes into force from the 2019 report. It must be provided by the following persons:

• business entities operating in the field of industrial and consumer waste management;
• regional operators for the management of municipal solid waste (hereinafter referred to as MSW);
• MSW management operators.

Let us recall that previously this form was submitted by a wider range of people (comparison of three regulations regarding requirements for the range of persons):

Thus, economic entities related to SMEs should not submit Form 2-TP (waste), provided that three conditions are simultaneously met for them:

• only MSW weighing less than 0.1 tons is generated;
• an agreement has been concluded with a regional operator for the management of MSW;
• There are no activities for processing, recycling, neutralization, or disposal of waste.

Form 2-TP (waste) must be submitted to the Rosprirodnadzor TO by February 1. In general, the differences in the new order are insignificant; for example, more detailed explanations have been given on the issue of who should fill out this or that section of the form and in what cases, and the form of some sections has changed.

Declaration on fees for negative environmental impact in 2021

As part of environmental reporting 2021, this declaration, the procedure for its submission and form have not changed. According to the law, the following categories of persons are required to file a declaration and pay a fee:

Federal Law of January 10, 2002 N 7-FZ) “On Environmental Protection”

Article 16.1. Persons obligated to pay fees for negative environmental impact

1. Payments for negative impacts on the environment are required to be made by legal entities and individual entrepreneurs carrying out economic and (or) other activities that have a negative impact on the environment on the territory of the Russian Federation, the continental shelf of the Russian Federation and in the exclusive economic zone of the Russian Federation (hereinafter referred to as - persons obligated to pay a fee), with the exception of legal entities and individual entrepreneurs carrying out economic and (or) other activities exclusively at objects of category IV.

Payers of fees for the negative impact on the environment when disposing of waste, with the exception of solid municipal waste, are legal entities and individual entrepreneurs whose economic and (or) other activities generated waste. Payers of fees for the negative impact on the environment when disposing of municipal solid waste are regional operators for the management of municipal solid waste, operators for the management of municipal solid waste, carrying out activities for their disposal.

The deadline for filing the declaration is March 10, the deadline for paying the fee is until March 1.

According to clause 1 of Article 4.2 of Federal Law No. 7-FZ, legal entities and individual entrepreneurs who operate at Category IV facilities (in accordance with the criteria of Decree of the Government of the Russian Federation No. 1029 dated September 28, 2015) do not need to pay a fee for the NVOS. Those users of natural resources whose objects do not have a category currently have to pay a fee, since clarifications to the Criteria for determining the category of an object have not yet been made, and many objects find themselves in a legal vacuum.

Regional operators pay for the disposal of MSW at landfills. By January 1, 2021, all constituent entities of the Russian Federation were required to switch to a new MSW management system in accordance with regional programs in the field of waste management and territorial waste management schemes, as well as select a regional operator. According to the law, when placing production and consumption waste at waste disposal sites that exclude a negative impact on the environment and are determined in accordance with the legislation of the Russian Federation in the field of waste management, no fee is charged for the placement of production and consumption waste.

From January 1, 2021, when calculating the fee, the provision of Part 5 of Article 16.3 on additional coefficients comes into force:

That is, for objects of categories I and II from 2021, for violation of the standards of NDV, VSV, VAT, VSS, the fee will be charged 25 times and 100 times. Category II facilities that have submitted an EIA pay for the volumes and masses of emissions and discharges indicated therein. If they are exceeded compared to those specified in the DOIA, you will have to pay 25-fold and 100-fold. For objects of category III, the fee for the NVOS will be charged without increasing factors in case of timely submission of the above-mentioned reports on waste generation.

Among the new products this year in the field of paying fees, we can note the emergence of the long-awaited procedure for offset and return of amounts of overpaid (collected) fees, approved by Order of Rosprirodnadzor dated June 20, 2019 N 334″. According to this order, the offset of the amounts of overpaid (collected) fees is carried out according to those types of negative impact on the environment (budget classification codes), as well as according to the OKTMO codes by which the fee was calculated and paid. The offset is carried out by Rosprirodnadzor at the location of the NDC facilities upon application no later than 3 months from the date of receipt of the application. In this case, you first need to sign a reconciliation report with Rosprirodnadzor without disagreement.

More information about the NVOS

Environmental Impact Declaration

The NVOS declaration is submitted by organizations operating objects of category II, in the case of belonging to the Federal State Environmental Supervision - to the territorial bodies of Rosprirodnadzor of St. Petersburg, in other cases - to the executive authorities of the constituent entities of the Russian Federation.

The NVOS declaration is directly a permitting document for objects of category II, so there is no need to obtain additional permitting documentation.

The level of supervision and categorization are indicated in the certificate of registration of the NVOS facility.

The return can be filed in writing or electronically, but the latter will require an enhanced, qualified electronic signature. The IEE declaration will be valid for 7 years after its submission if a number of processes remain unchanged:

• Key technological processes of the enterprise;

• Quality and quantity of emissions and discharges of pollutants, as well as stationary sources.

Calculations of permissible emission standards and permissible discharge standards are appendices to the NVOS declaration, and therefore are submitted together. Please note that standards are approved only by the organization.

The initial deadlines for filing the declaration have not been established, since according to the law the previous permitting documentation is still in force:

• Permits for emissions of pollutants;
• Permits for pollutant discharges;
• Standards for waste generation and limits on their disposal.

The date of submission of the DVOS is limited to the validity period of the above permits.

Reporting under the PEC program in 2021

Reporting under the industrial environmental control program is an annual report on the implementation of the IEC program for objects of categories I-III. The PEC program includes control over emissions into the atmosphere, discharges into water bodies, and waste management activities. Order of the Russian Ministry of Natural Resources dated June 14, 2018 N 261 approved the reporting form for PEC. Reporting on PEC activities carried out must be submitted by March 25, 2021.

In October 2021, methodological recommendations for filling out a report on the PEC program appeared, contained in Order No. 522 dated October 16, 2021; in accordance with the letter of the Ministry of Justice of Russia dated December 29, 2021 No. 01/171702-102, they did not require state registration. In November 2021, the recommendations were published on the official online legal information portal. They can help you understand how to complete report tables to meet the 2021 environmental reporting standards.

More about PEC