It is proposed to standardise the manufacturer’s (importer’s) responsibility by introducing standards for disposal and for environmental charges, together with alternative strategies (way) being offered to the producer (importer) of lubricants for meeting the legislative requirements: independently or by paying an environmental charge.
The new legislative developments are essentially designed to encourage the manufacturer (importer) of lubricants to perform and management the life cycle of the lubricants. Those of who drafted the amendments to [2] failed, however, to take into consideration that producers (importers) of lubricants that launch the life cycle of the lubricants put exclusively fresh oil on the market. It is with the consumer that the oil becomes used oil, i.e., the goods become waste.
Because of the end consumer’s commercial activities, the fresh oil loses its performance attributes. By making the producer (importer) of lubricants exclusively responsible, those who drafted the changes to [2] enshrine a contradiction in the mechanism for recycling used oil and other waste, since the end consumer is required to hand over the used oil (waste) for disposal by the producer (importer) of the lubricants or made responsible for doing so.
In fulfilling these revolutionary legislative developments, producers (importers) of lubricants bear a triple burden of responsibility:
a) towards shareholders: for ensuring development of the lubricants business and further growth of the company’s capitalisation;
b) towards the federal executive authorities: for meeting the requirements of the regulatory and legal acts;
c) towards the environment in Russia: for reducing the technogenic impact of their output.
Essentially, therefore, the amendments to the regulatory and legal acts constitute an environmental challenge for producers (importers) of lubricants in Russia. Consequently, the lubricants business in Russia faces the following tasks:
a) to evaluate draft requirements of regulatory and legal acts and problematical spheres of handling of used oil in Russia, as presented in fig. 2;
b) to respond appropriately and adapt the lubricants business in good time to the requirements of the regulatory and legal acts.
Timely fulfilment of these tasks would permit an effective response to the environmental challenge.
Producers (importers) lubricants are required to provide waste disposal from the use of these products in accordance with the norms utilisation established by the Government of Russia.
It should be noted that analysis of the new version of bill [2] shows that the new developments offer the producers (importers) of lubricants different ways to fulfil their responsibility for environmentally safe removal or their products that have lost their consumer attributes (for the lubricants business, this means used (waste) oil):
First - independently, by organising their own infrastructure facilities for collecting and utilising used (waste) oil in accordance with the procedure established by the Government of Russia;
Second - by paying an environmental contribution into the state budget for handling consumer waste;
Third - by concluding direct agreements with operators handling waste (in their own name, at the expense of the producer (importer) of the goods to be disposed of).
The choice of method determined the strategy pursued by the producer (importer) of lubricants in Russia in response to the environmental challenge:
Strategy No .1 - Independently by organising its own
infrastructural units involved in gathering and disposal of used (waste) oil; Strategy No
state budget; Strategy No
.3 - Direct contracts with the operators of waste management and payment for their services.
.2 - Payment of the environmental contribution to the
Figure 2. Problematical sphere of used (waste) oil handling in Russia Continued on page 30 LUBE MAGAZINE NO.126 APRIL 2015 29
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