The environment is costly – and so are violations.
In recent years, the Ministry of Environmental Protection has intensified its administrative enforcement activities. The Ministry is authorized to impose financial sanctions for breaches of various environmental laws, including infringements that may sometimes be perceived as merely “technical”, such as failing to submit a report on time or failing to enter into a required contractual arrangement.
The firm represents companies, importers and manufacturers in proceedings concerning financial sanctions imposed under environmental legislation, including the Regulation of the Treatment of Packaging Law, 2011, and the Disposal and Recycling of Tires Law, 2007. Representation is provided from the initial administrative objection stage and throughout the proceedings before the relevant authority, as well as, where necessary, in administrative petitions or appeals to the courts against the imposition of a sanction.
In an administrative petition decided in 2025, the court accepted the firm’s argument that, in appropriate circumstances, a financial sanction imposed under the Tire Law could be reduced even though no regulations governing such reductions had been enacted under that law. The court rejected the Ministry of Environmental Protection’s position that, in the absence of specific reduction regulations, the sanction was a fixed amount that could not be reduced [Administrative Petition (Jerusalem District Court) 51424-04-25, J. Kimchi Ltd v. Ministry of Environmental Protection (16 November 2025)].
One of the most common sanctions in this field is imposed on importers and manufacturers that have not entered into an agreement with the recycling corporation T.M.I.R. for the fulfilment of their obligations concerning the collection and recycling of packaging waste, including cardboard, plastic and glass packaging. These sanctions may be substantial and can exceed NIS 100,000.