Certificates and Declarations Marked "as amended on 23.12.2021" Stop Working on 1 September 2026: What It Means for Shipments to Russia
In brief. From 1 September 2026 part of the currently valid Russian certificates of conformity and declarations of conformity stop working: the register moves them to "archived" status. These are documents issued under the requirements that applied before the changes introduced by Russian Government Decrees No. 642 of 14 May 2025 and No. 1403 of 11 September 2025. Such a document is easy to recognise — its "object of certification/declaration" section carries the note "as amended on 23.12.2021". Goods already released into circulation while the document was valid can still be sold and used until the end of their shelf life or service life. The change hits your future shipments: your Russian buyer will need a document issued under the current requirements before your cargo is declared at customs. Less than three weeks are left, so this is a check for this week, not for later.
1. What changes on 1 September 2026
In 2025 Russia amended certain requirements for products subject to mandatory certification and declaration of conformity. Documents issued and registered before those amendments entered into force confirm compliance with a wording of the requirements that is no longer current. That is why a single cut-off date has been set for them: from 1 September 2026 they cease to be valid and receive the status "archived" in the register of issued certificates of conformity and registered declarations of conformity.
It is worth reading that status correctly. It is not a withdrawal of the document and not a retroactive finding that the product is unsafe. Archived means one thing only: from that date the document can no longer be used as valid proof of conformity. Everything already released into circulation while it was valid stays legal goods and keeps being sold within its shelf life or service life.
For you as the shipper the consequence is purely forward-looking. In Russia the permit document is required at the moment of customs declaration, and the customs authority checks it against the register. If the document is already archived when the declaration is filed, it cannot be quoted as valid — and the consignment stops at the border or at a temporary storage warehouse. From there the clock starts on storage, demurrage and detention, and on whoever carries those costs under your contract. For regular suppliers planning autumn shipments this is not document housekeeping; it is a delivery-date risk.
2. How to tell whether the document behind your goods is affected
The marker is simple and visible without any expertise. The card of the certificate or declaration in the Rosaccreditation register has a section called "object of certification/declaration". If it carries the note "as amended on 23.12.2021", the document was issued before the amendments came into force — so it will be archived.
If there is no such note, the document was issued under the current requirements and stays valid until its own expiry date. Nothing needs to be done about it.
What exporters most often get wrong when checking:
- Ask for the register number, not a PDF scan. A scanned copy shows the expiry date, but the amendment note and the current status can only be seen in the register card.
- Expiry date is not the same as validity. A card can say the certificate runs for another two years and still be moved to the archive on 1 September — the limitation here is about the wording of the requirements, not about time.
- Find out who actually holds the document. If it is held by you as the manufacturer or by your authorised representative in Russia, re-issuing it is your job and your timeline. If it is held by the importer or a distributor, ask them for the register number in writing.
- Check the object, not just the number. One document usually covers several models or article numbers; make sure the entire range you ship is genuinely inside it, including items added to the range later.
- Cover the whole product list, not a sample of it. A supplier with a broad range easily accumulates dozens of declarations, and the old ones sit mixed in with the new.
If part of the documents has to be re-issued, it makes sense to work out straight away which tests and which certification scheme are needed — that is where the time goes, not in filing the application. Our certification department can assess this and handle the re-issue.
From 1 September archived certificates and declarations can no longer be presented to Russian customs
3. Shipment scenarios: what happens and what to do
Below are the typical positions suppliers to Russia are in right now. The starting point is whether the document covering your goods carries the "as amended on 23.12.2021" note, and when the nearest consignment will actually be released by customs.
Certificates and declarations are not cancelled retroactively, but from 1 September 2026 they stop proving conformity at customs clearance — so what matters is the release date of your cargo, not the date you ship it.
| Your situation | What happens after 1 September 2026 | What it means for you as the shipper |
|---|---|---|
| Goods already released by Russian customs and in circulation (warehouse, retail, end customers) | The document is archived, but the goods entered circulation while it was valid | Nothing to re-issue. Your buyer keeps selling them within the shelf life or service life |
| Cargo in transit, release expected before 1 September | The document is still valid at the moment of declaration | Send the complete shipping set immediately so the declaration is not delayed; in parallel start a new document for the following batches |
| Cargo in transit or under contract, release falls in September or later | An archived document cannot be quoted as valid | A new document under the current requirements must exist before the cargo arrives — release samples and technical files for testing now |
| Regular shipments of the same range | The old document no longer covers new consignments | Top priority: this is your running business and it stops first |
| The register card has no "as amended on 23.12.2021" note | The document stays valid until its own expiry date | No action needed — just record the check result and the register number |
| The item is discontinued for the Russian market | The document is archived | No re-issue needed if no further shipments are planned |
Pay particular attention to long transit legs. Sea freight from Asia and rail shipments easily push the actual customs release a month to six weeks beyond the shipping date — so a container leaving today "under a valid document" will arrive into the new rules.
4. What the exporter should do
- Ask your Russian buyer for the register numbers of the certificates and declarations under which your goods are declared — per product, not one number for the whole contract.
- Have every card checked for the "as amended on 23.12.2021" note and get the answer in writing. If you or your authorised representative is the document holder, check it yourself.
- Map the affected list onto your order book to the end of the year. The priority is everything whose customs release falls in September or later, plus your regular repeat items.
- Prepare the technical file now. Product description, the full list of models and article numbers, composition or materials, drawings and specifications, manufacturing site details, existing test reports and quality certificates — this is what the certification body will ask for first.
- Reserve samples and be ready to send them fast. Testing is the long, least controllable part of the process, air freight for samples is usually the quickest route, and laboratories are busier than usual ahead of a common cut-off date.
- Confirm the range coverage. If you have added models or article numbers since the original document was issued, they may not be covered at all — a separate problem that surfaces at the same border.
- Agree the commercial side in writing with your buyer. Who applies for and pays for the new document, and who carries storage and demurrage if a consignment cannot be released. Under most Incoterms terms this lands on one specific side — better decided now than at the warehouse.
- Re-plan borderline shipments. If the new document will not be ready in time, moving the departure date is usually cheaper than paying for cargo that sits and cannot be cleared.
If the range is large and there is no time to untangle it from abroad, this work can be delegated together with customs clearance in Russia — document checks and declaration filing then run as one process instead of drifting apart.
From 1 September old certificates and declarations move to the archive: they can no longer be presented to customs
5. Frequently asked questions
Our goods are already in Russia and on sale. Does the document have to be re-issued urgently?
No. Products released into circulation while the document was valid continue to be sold and used within their shelf life or service life. A new document is needed for new consignments.
What does "archived" mean — is the document void retroactively?
No. Archived status records that from 1 September 2026 the document is no longer valid and cannot be used as proof of conformity. It does not affect deliveries that have already been cleared.
The document is held by our Russian importer, not by us. Is this still our problem?
Practically, yes. The document is what allows your cargo to be released, so if it goes to the archive your shipment is the one that stops. And the re-issue almost always needs something only the manufacturer can provide: samples, the technical file, production site data. The earlier you are asked, the earlier you can ship the samples.
Our certificate card has no "as amended on 23.12.2021" note. Are we fine?
Yes, that document was issued under the current requirements and runs to its own expiry date. Still check the whole range — a supplier portfolio usually contains both kinds.
The new document clearly will not be ready by 1 September. What do we do with the cargo?
Work back from the expected customs release date, not from the sailing date. If release falls after 1 September, plan the shipment around the readiness of the new document rather than the other way round. Sometimes moving the departure is cheaper than paying storage for goods that cannot be released. Assessing the timeline for a specific product range and building the logistics around it is best done before the container is at sea.
Summary
From 1 September 2026 certificates and declarations marked "as amended on 23.12.2021" move to archived status and stop being valid. Goods released into circulation earlier stay on sale until the end of their shelf life or service life, but every new consignment will need a document issued under the current requirements. Checking the register takes a few hours; re-issuing takes considerably longer, and your cargo is the thing that waits. Leave a request for a consultation and we will go through your specific shipment.
Our certification team can check the register cards behind your products and start the re-issue before your next shipment leaves.
Read also:
- Certificates and SGR: the Russian permits that decide whether your shipment clears the border
- Shipping dietary supplements to Russia: Chestny ZNAK codes, documents and what your buyer will now require
- Russian Decree No. 867 explained: what changed on 9 August for goods subject to mandatory conformity assessment — and what your buyer will now need from you
- From 10 August Russia extends simplified certification to 2027 — and tightens the rules for goods on Minpromtorg List No. 4114: what it means for your shipment
