The introduction of the National Pollutant Release and Transfer Register (PRTR) was complicated by the large-scale war, in particular, personal identification was introduced to access it and the coordinates of facilities were hidden.
This information is contained in the draft National Report on the Implementation of the Protocol on Pollutant Release and Transfer Registers 2025 (for the period 2021-2024), published on the website of the Ministry of Environmental Protection and Natural Resources of Ukraine.
The report contains 16 articles with answers to the following questions:
- existing legal framework;
- measures to comply with reporting requirements;
- legislative, regulatory and other measures that ensure data collection and record keeping;
- rules, procedures and mechanisms ensuring the quality of data contained in the national PRTR;
- the manner in which public access to the information contained in the register is ensured;
- other issues related to the functioning of PRTR.
Difficulties in the conduct of the Ukrainian PRTR
In the document, experts of the Ministry of Environment noted that one of the problems that arose during the implementation of the National PRTR was security measures, since critical infrastructure facilities were among the first to suffer as a result of military aggression by the Russian Federation against Ukraine. Because of this, personal identification was carried out to access the National PRTR, because it contains important information that the enemy can use for their own purposes.
"However, the public part is removed from the National PRTR and becomes available without identification," the report says.
The register functions as an online service on the Unified Environmental Platform "EkoSistema":
Screenshot from eco.gov.ua.
You can familiarize yourself with the data contained in the National Register of Emissions and Transfer of Pollutants at link.
Based on the data of the first reporting year of 2023, with the help of electronic tools of EcoSystem, the Ministry formed comprehensive report on emissions and transfers of pollutants and waste in 2023. It was published on the official website of the Ministry of Environment for all interested parties to familiarize themselves with. It will be recalled that it caused a lot of criticism from experts and activists, as it contained errors and did not reflect the real situation, as many operators did not submit their data.
The report notes that due to the introduction of martial law in Ukraine, business entities are currently not required to submit reports and may report even after the end of the reporting period. Resolution of the Cabinet of Ministers No. 560 envisages only electronic reporting in order to facilitate the input of information and exclude the transfer of documents in paper form.
The ministry said that the first reporting year according to the Law of Ukraine "On the National Register of Emissions and Transfer of Pollutants" was 2023. It was also the year of entry into force of the regulations on the National PRTR, so Ukraine was able to present its achievements only during the Working Meeting of the Parties to the Protocol on Emission Registries and Pollutant Transfers in 2023 and 2024 in Geneva, Switzerland.
Integration with the European register: to be or not to be?
It is worth noting that the Ministry of Environment constantly postpones the integration of the National Register of Emissions and the Transfer of Pollutants of Ukraine to the European Register "Guidance Document for the implementation of the European PRTR". So, at the beginning of June 2023, the then Minister of Environmental Protection and Natural Resources of Ukraine Ruslan Strelets stated that "in two years the Ukrainian National PRTR will be integrated with the European one". However, in March of the following year (that is, almost a year later), the Ministry of Environment was under his leadership again called the same term is 2 years.
In the draft of the National Report on the implementation of the Protocol on Emissions and Transfers of Pollutants 2025, the integration of the National PRTR with the European PRTR and the dissemination of information on the OECD dashboard were named among the plans.
On September 20, 2022 Verkhovna Rada approved in the second reading, the government draft law No. 6477 "On the National Register of Emissions and Transfer of Pollutants". In October 2022, the document signed by the president Volodymyr Zelenskyi of Ukraine, and it entered into force on October 8, 2023, and polluting enterprises within 6 months were obliged to enter data about their objects into the RTD.
In June 2023, EcoPolitics reported on approval of the Cabinet of Ministers on the Procedure for Keeping the National Register of Emissions and Transfer of Pollutants.
In March of this year, the Ministry of Environment approved Methodological recommendations on the procedure for drawing up the report of the authorized body and Methodological recommendations on the procedure for drawing up and submitting the operator's report.
