This regulation came seven months before the Russian government proposed a bill for nationwide collection and treatment of waste lubricants as a way to harmonize with the unions action. According to the Energy Ministrys August 2013 explanatory memorandum of the draft, in Russia waste lubes are used nationwide for heating, as fuel, added to marine fuels or used as soaking and coating elements in the production of construction materials. It went on to indicate that combusted or evaporated waste lubes contaminate the atmosphere with dangerous elements and heavy metals such as lead, cadmium, vanadium and mercury.

One would think that such a strong statement from the Ministry of Energy would lead to a public outcry and engagement of various government bodies, nongovernmental groups or industry players to propose concrete steps for long-delayed moves to preserve the environment. But surprisingly, the draft bill is still under review, according to the Energy Ministrys 2014 annual report.

EU vs Russia

It is widely known that Russia is not a champion of environment protection. In fact, unregulated landfills, waste dumps and oil spills in the soil and waterways are common in the countrys wastelands, sparsely populated regions and in megacities.

Russia is not Europe, where only 25 percent of the 2 to 3 million tons of waste lubes generated annually are either burned or end up in the sewer and waste water systems, according to Amsterdam-based consultancy Ivam. In Russia, About 10 percent of the 1.1 million tons of used lubricants generated annually are used as fuel, while a staggering 85 percent is discharged into the environment, Svetlana Erkenova of the State Duma (the lower chamber of the Russian parliament) Energy Committee told GBCs CIS Base Oils, Lubricants and Fuels conference in Moscow in May. In the European Union, around 40 percent of the collected waste lubes are processed into rerefined base stocks, whereas in Russia just 5 percent is rerefined, she said.

Despite the hazardous consequences to the environment and to peoples health, the only action is the bill that went into effect earlier this year. This regulation thoroughly amends the 1998 law that mandates treatment and handling of various industrial and consumer wastes. The amended bill was signed into federal law on December 29, 2014, and it went into effect on January 1.

Although the regulation is devoted to waste in general (the expressions used oils or lubricants are not mentioned in the bills text published on the Kremlin website), some industry insiders saw in it another opportunity for the countrys lube producers to get closer to European standards and encourage life-cycle management of their products.

The law is an essential guideline for the collection and processing of used oils, Rodion Cherednichenko of the Moscow-based Association of Waste Recycling told the conference. At the moment, what is most important for Russian rerefiners is to search for and choose appropriate technologies, he said. Cherednichenko also owns Russian rerefiner Rosa-1.

Ineffective Legislation

What the new regulation certainly does is promote the idea of waste utilization. All other environmental rules passed since the collapse of the Soviet Union – such as those in the early 1990s and throughout the 2000s – deal with the introduction of pollution fees, promotion of technologies that ensure minimum impact or introduction of permits to environmentally hazardous companies. No single legislation deals with recycling or waste utilization.

Furthermore, some of the environmental protection laws passed in 2002 and measures for energy and environmental efficiency executed from 2008 to 2014 amount to mere action plans. They lack clear focus for handling and treatment of certain wastes such as used lubricants. Such an ambiguous action plan is the government executive order of April 2014 for the reduction of greenhouse gasses by 2020 to 75 percent of the level registered in 1990.

The January law, in contrast, sets targets for volumes of waste products to be recycled and introduces the concept of environmental taxes that could be assessed, for example, on units of finished lubricants sold. What we should do now is implement these concepts into rules that would encourage the development of countrywide collection and recycling of used lubricants, Cherednichenko said.

The association urged the government to introduce targets for volumes of used goods that should be recycled. For example, in 2015 we should aim to utilize 10 percent of all produced and imported used goods, including lubricants. This figure should increase to 15 percent next year and 25 percent in 2017.

The association also proposed setting a minimum of waste oil products to be delivered for recycling in Russia. For example, at least 40 percent of used industrial oils and 48 percent of transmission fluids should be recycled, the group said, as well as about 40 percent of gasoline engine oils and 35 percent of diesel engine oils.

The appropriate rate for an environmental tax for manufacturers and importers of commercial oils in Russia is still being debated, and the association cited figures for lubricating oils proposed by the Moscow Higher School of Economics. The school suggested a rate of 249 rubles (4) per ton for 2015, increasing to 766 rubles/ton in 2024.

The Only One

Rosa-1 owns the only rerefinery in Russia. It is located in Ryazan and can process 40,000 tons of waste oil per year to produce API Group I base oils and commercial lubes. It is also the only independent Russian rerefiner that has an established network of used oil collection points in several Russian cities, including Moscow, Ryazan, Samara, Volgograd, Yekaterinburg, Vologda, Novokuznetsk and St. Petersburg.

According to the association, 25 percent of Russias used lubes are merely filtered and then reapplied as low-quality industrial oils or as coolants. They are also used as roofing and road materials. Forty percent is used as fuel in heating or power units, and 31 percent is discharged in waterways or landfills. The rest, or just 4 percent of Russias used oils, is processed into rerefined base oil.

In its own research, Rosa-1 data found that 576,000 tons of used lubricants are collected in Russia annually. Forty percent of this volume is automotive lubes, and an equal amount were industrial lubes. Other used lubricants come from hydraulic (8 percent), electrical (6 percent) and transmission (2 percent) applications. Other uses account for the remaining 4 percent.

The Russian Federation is divided into nine federal districts, and some of them are major generators of used oil. Rosa-1 also found that the Central district that encompass Moscow and Moscow oblast accounts for 26 percent of the used oil collected in the country. Other major districts for used oils collection are Volga with 19 percent, followed by the Ural district with 18 percent, Siberian with 12 percent and Northwest with 10 percent.