EPR In Central Eurasia - A Test for State Capacity

Central Eurasia is undergoing a profound institutional shift in waste governance, transitioning from fragmented, “polluter-pays” environmental taxes to robust, operationalized Extended Producer Responsibility (EPR) schemes.

As of early 2026, the region is moving beyond the declaratory phase, where legislation existed largely on paper, toward an era of fiscal and operational enforcement. Producers and importers across the seven markets analyzed– Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Tajikistan, Uzbekistan– must recognize that EPR is no longer a peripheral compliance issue but a core pillar of market access with different EPR models. Kazakhstan and Kyrgyzstan rely on a state-centered model in which a public operator collects fees and verifies compliance. Armenia and Georgia lean toward EU-style collective responsibility exercised through Producer Responsibility Organizations (PRO). Armenia and Georgia have moved closer to EU-style collective responsibility through Producer Responsibility Organizations. Uzbekistan, Azerbaijan, and Tajikistan remain at earlier stages, where the legislative scope, administrative capacity, and the development of recycling infrastructure are yet to be built.

Packaging is the one waste stream that appears across virtually every established or proposed system in the region. Plastic, glass, paper, cardboard, metal, and composite packaging are already covered, or are expected to be covered, under various national schemes.

Kazakhstan runs the region’s most institutionalized EPR system, treating producer responsibility primarily as a financial and documentary duty rather than performed by the state. Article 386 and the implementing EPR rules require producers and importers of designated goods and packaging to ensure collection, transportation, preparation for reuse, sorting, processing, recycling, neutralization or disposal after products lose consumer properties. JSC Zhasyl Damu acts as the state operator, while the Ministry of Ecology and Natural Resources establishes the regulatory framework.

The EPR regimen in Kazakhstan provides two compliance routes: independent and operator-based contracting. In other words, producers may organize their own collection and recycling system or transfer the obligation to the operator through a contract, application and utilization-fee payment. From one side, the independent route is administratively demanding. Documentation must be submitted every six months by the twentieth day of the month following the reporting half-year and must substantiate collection, transportation, processing and production. Furthermore, verification then passes through the Ministry of Ecology, the Ministry of Finance and the operator, with the full review cycle potentially taking up to 36 calendar days. This administrative path reflects a centralized documentary verification and audit while delegating physical waste handling.

On the other hand, the operator route is simpler but more fiscal. Under Order No. 448, the utilization fee is calculated using the mass of goods or packaging, the monthly calculation index (MCI) and a coefficient assigned to the relevant category of the commodity. Exemptions include exported goods, qualifying packaging containing at least 30% domestically recycled secondary material, specified socially significant food products, certain goods imported for own fixed-asset use and polymer packaging made from preforms on which the fee has already been paid.

The institutional design also provides an access point for the organized interests to participate in policy discussions. For instance, associations such as KazWaste and the Association of Recyclers represent producer and recycler interests, creating a channel for interest intermediation alongside a highly centralized operator model.

On the other end of utilization fee, the design transfers fee revenue to build and modernize recycling infrastructure across the regions. In turn, such initiatives address increasing waste, connected to growing consumption rates and demand for delivery services, resulting in more packages. With the utilized municipal waste being 30.6% in 2025, the Waste Management Concept for 2026 to 2030 plans to expand an inventory of 50% of non-radioactive waste by 2027 and 100% by 2028, while municipal waste sent to landfill should fall by at least 10% against the 2025 baseline by 2030.

Kyrgyzstan has converted EPR law into an operational payment system as well. The 2023 Law on Production and Consumption Waste and Cabinet Resolution No. 322 form the core framework, with mandatory obligations operating from 1 January 2025. The regime covers 24 product groups, including electronics, batteries, tires, oils and plastic, composite, paper and cardboard packaging.

Following the similar framework between independent and operator-based routes, producers can choose to either recycle independently or transfer those obligations to the state Eco-Operator. Importers must pay within 15 calendar days of customs clearance, while domestic producers report and pay quarterly by the fifteenth day of the month following the reporting quarter. Notably, goods and packaging exported from Kyrgyzstan are excluded from the fee base. Under independent compliance, utilization must be documented through authorized recyclers while failure to achieve the utilization norm converts the physical shortfall into a financial liability.

Kyrgyzstan’s Ministry of Natural Resources, Ecology and Technical Supervision sets policy while the Eco-Operator administers registers and payments. Implementation is now visible in fiscal data. Official January to May 2026 figures reported KGS 132.1 million (USD 1.5 million) in fee revenue, compared with KGS 16.7 million (USD 191 thousand) during the same period of 2025, while the number of payers increased from 50 to 259. Therefore, enforcement is becoming observable, suggesting both administrative and enforcement capacity within EPR regulation.

Uzbekistan is on a development stage towards a centralized environmental and waste-management governance framework. The general legal framework remains the Law on Waste and the Law on Nature Protection, while Presidential Resolution No. PP-171 provides the legal basis for the phased introduction of “extended obligations” for producers and importers from August 2026. Under Annex 6 and 7, the scheduled scope includes oils, plastic packaging and closures, tires, glass containers, batteries and lighting products, while imported packaged goods are additionally covered across plastic, glass and composite packaging materials. The resolution requires the relevant waste to undergo phased collection, utilization and/or recycling by producers and importers. However, it does not itself establish a complete operational EPR architecture, including detailed compliance targets, producer registration, collective compliance arrangements or fee methodology.

The main regulating actor of the EPR in Uzbekistan is the National Committee on Ecology and Climate Change, which is directly accountable to the President. Meanwhile, the updated Uzbekistan-2030 framework targets 90% population coverage by municipal solid-waste collection services, a 7% increase in household-waste recycling, and at least a 50% reduction in the number of municipal waste landfills. Although the effectiveness of the regime will depend both on the adoption or clarification of implementing mechanisms, Uzbekistan can be characterized as having entered the initial implementation phase of EPR.

Tajikistan’s waste management is governed primarily by the Law on Production and Consumption Waste, supplemented by sector-specific rules. These legislative bases, however, do not establish EPR obligations for producers or importers. Instead, EPR is currently at the policy formulation stage, with the consultations from international development institutions, such as ADB, EBRD, UNDP, World Bank and JICA.

Starting from the National E-Waste Roadmap for 2025-2029, the Committee for Environmental Protection recently presented a draft of the “Municipal Waste Management Strategy to 2040” and accompanying 2026-2030 action plan. The proposed “Waste Management Strategy to 2040” emphasises the alignment of the national regulatory framework with the principles of the circular economy and EPR, alongside the modernisation of waste-management infrastructure. Key priorities include the development of sanitary landfills, the introduction of waste-to-energy and recycling technologies, strengthened systems for the safe management of hazardous, medical, electronic, and construction waste, and the establishment of digital monitoring mechanisms to improve transparency and accountability in the sector. Thus, it is still expected for Tajikistan to diverge EPR from the general waste management policies and provide necessary infrastructure for producers and importers.

Armenia illustrates Europeanization mediated through domestic institutions as the state is attempting to move from a tax-centered system toward EU-aligned collective responsibility. In June 2026, the Ministry of Environment published a revised EPR legislative package, which would make producers and importers responsible for post-consumer waste through individual compliance or collective Producer Responsibility Organizations (PRO). The draft law covers separate collection, transportation, storage, reuse, recycling, utilization and safe disposal of designated waste streams. Therefore, the proposed PRO model would internalize collection and treatment costs by pooling producer financing and coordinating waste management with municipalities and specialized PRO operators.

As in Tajikistan, Armenia’s EPR policy development is being conducted with the assistance from external consultants. The Acopian Center for the Environment, with Swedish support, provides technical assistance to the Ministry, while a June 2026 stakeholder session brought together state institutions, businesses and technical experts. Armenia therefore represents a gradual EU-aligned transition, who is yet to develop authorizing PROs, setting credible targets, and clarifying collisions between EPR obligations and existing tax.

Azerbaijan’s current waste management strategy consists of narrow administrative product restrictions rather than focused on comprehensive EPR policy. For example, existing rules prohibit polyethylene bags below 15 microns and specified single-use plastic products, while bags between 15 and 50 microns must be charged separately at retail. For violations of the rules, legal entities can face fines of USD 1,765 to 2,353 (AZN 3,000 to 4,000). Vehicles are the only commodities to be utilized, where payment applies to specified imported vehicles, including those that are more than four years old, at customs clearance.

In 2026, a Presidential Decree established a State Agency for Waste Management within the Ministry of Ecology and Natural Resources. The Agency was assigned regulatory control and waste-fee functions across the full waste cycle. The same decree required proposals amending the Law on Waste within four months and a National Strategy for Solid Waste Management for 2027-2030 within five, making the fourth quarter of 2026 the moment Azerbaijan's EPR timetable becomes legible.

Georgia offers the South Caucasus’ clearest example of EPR shaped by European approximation and its clearest demonstration that stable policy direction can coexist with negotiable deadlines. Article 9 of the Waste Management Code establishes producer responsibility, operationalized through four technical regulations covering electrical and electronic equipment, batteries and accumulators, tires, and waste oils. Producers must register in the electronic EPR register and join an authorized PRO or run an approved individual system, and distributors may not place goods on the market for unregistered producers. Unlike the Kazakh or Kyrgyz operator model, charges are generated within the collective scheme rather than as a single state fee. The Ministry of Environmental Protection and Agriculture administers the system and continues to enforce the region's largest penalties up to USD 19,200 (GEL 50,000) per day per violation.

Packaging represents an adjacent policy frontier managed through direct prevention measures, where the timeline has proven to be highly political. While the ban on single-use cutlery, plates, straws, and expanded-polystyrene containers took effect on 1 January 2026, the government of Prime Minister Kobakhidze subsequently postponed the restrictions on food-service containers to 1 January 2027, cups to July 2027, and a total prohibition of plastic beverage bottles to 1 February 2031, citing business consultations regarding substitution costs. This adjustment signifies a negotiated implementation process rather than a reversal of the National Waste Management Strategy’s commitment to achieving 90% packaging recovery by 2030.

While across the region EPR is converging as a broad principle, its implementation remains a test of state capacity. The landscape has already transcended the era of purely declaratory legislation, entering a complex, high-stakes phase of operational and fiscal enforcement. While regional markets are converging on the fundamental principle of producer responsibility, the divergence in institutional models, ranging from centralized state-operator regimes to nascent, EU-aligned PRO structures, creates a fragmented environment that necessitates a sophisticated, localized approach to compliance.