Customs Value in Russia: Payment Dates and FX Rate Now Decide What Your Buyer Declares

1. What the letter changed

Your contract price is normally set in a foreign currency, while your buyer declares the customs value in rubles. Until now the conversion point was simple: the rate of the day the declaration was registered. The February letter splits one shipment into two parts with two different logics.

• Paid before the declaration is registered — the amount actually spent goes into the customs value, whatever the rate was on the payment day.
• Paid after the goods are released — the amount is recalculated at the rate of the declaration registration date.

The reasoning behind it is clause 10 of Article 38 of the EAEU Customs Code: customs value and the information used to determine it must be based on reliable, quantifiable and documented data. A payment that has already gone through is a fact; a payment that has not yet been made is an estimate. The practical consequence for you is that the paperwork proving when each part was paid is now as important as the amount itself.

2. A letter is not a law — and why that does not protect your cargo

The Ministry of Finance itself stated in letter No. 03-02-08/55114 of 24 July 2019 that its written clarifications contain no legal norms and no general rules specifying statutory provisions, and are not normative legal acts — regardless of whether they answer one applicant or an unlimited group of persons. In other words, the February letter is an opinion, not a rule.

That distinction matters in a dispute, but it does not move a container. Individual customs offices already apply the letter, and a shipment held for a customs value adjustment is held in real time while the legal argument runs on paper. An authorised commission at the Federal Customs Service is working on the question, and until the underlying acts are amended the safest assumption for a supplier is that the stricter reading will be applied to your consignment.

Split payments and the rate on the declaration date now decide the customs value your Russian buyer has to prove

3. Goods price and extra charges follow different rules

The EAEU Customs Code separates two things: the price actually paid or payable for the goods (Article 39) and the additions to that price (Article 40) — the charges your buyer pays on top of the goods invoice, for example separately invoiced delivery costs.

For additions, the EEC Board settled the matter back in 2023: under Decision No. 112 of 15 August 2023, the actual amount paid is taken into account if the payment was made in rubles before the declaration was filed. For the goods price the wording points the other way: EEC Board Decision No. 160 of 16 October 2018 requires the first subsection of box 11 “a” to show the price actually paid or payable in the invoice currency, and the second subsection to show that price converted into rubles at the rate of the declaration registration date. Clause 8 of Article 38 says the same — conversion at the rate in force on the day of registration.

4. How it works in practice and what your buyer will ask you for

Some customs offices read the February letter as covering the goods price itself and apply it on a “the higher, the better” basis: if the actual ruble payment came out above the value at the declaration-date rate, they correct upwards to the actual payment; if your buyer managed a favourable rate and saved money, they insist on the declaration-date rate. Either way the declared value is challenged rather than accepted, and the shipment waits.

The date of each payment now matters as much as its amount: an invoice that does not show which part was prepaid and when, or a payment confirmation without a clear value date, lets the inspector choose whichever conversion produces the higher figure — and your cargo stays at the border while that is argued out.

This is why your Russian buyer will start asking for documents you may never have been asked for before: invoices that split prepayment and balance instead of one total, separate invoices for goods and for services, payment confirmations with value dates that match the contract, and consistency between contract, invoice, packing list and transport documents. During a customs clearance check, any mismatch between these papers is treated as a reason to request more, and each request costs days of storage and demurrage. A buyer who can put a complete, self-consistent file on the table on day one is the buyer whose shipments move.

5. What the exporter should do

1. Show the payment structure on the invoice. State the prepayment amount, the balance and the due moment for each — not just a single total with “payment as per contract”.
2. Do not merge goods and services into one line. Delivery, handling and similar charges belong on separate invoices; they follow their own conversion rule and merging them makes both parts harder to prove.
3. Keep dates unambiguous. Invoice date, contract date and the value date of every payment confirmation must be readable and consistent; avoid backdating or reissuing invoices after a payment has gone through.
4. Agree the payment calendar against the arrival date. If a payment is due around the time the declaration will be filed, it is worth deciding with your buyer whether it lands clearly before filing or clearly after release, rather than in the grey zone.
5. Answer document requests fast. If your buyer asks for a payment confirmation, an amendment or a written clarification during clearance, hours matter — the goods are already at the border.
6. Check the file before shipping. A pre-shipment review of contract, invoices and payment terms is far cheaper than a customs value adjustment on arrival. Our logistics and customs team does this for suppliers shipping into Russia and the CIS.

6. Frequently asked questions

My contract is in USD or EUR. Does this concern me at all?
Yes. The conversion into rubles happens on your buyer's side, but the inputs are your documents: the currency of the invoice, the split of the amounts and the date of every payment. The letter only changes which of those dates is used.

We work on 100% prepayment before shipment. What changes?
Your whole amount will normally fall into the “paid before the declaration is registered” category, so the actual ruble amount your buyer spent is what enters the customs value. Make sure the payment confirmation clearly matches the invoice for that shipment.

We only get paid after the goods are released. Are we affected?
That part is converted at the rate of the declaration registration date, which is the familiar rule. The risk is documentary: your buyer must be able to show that the amount was genuinely payable after release.

Is this a new law we should build into our contracts?
No — it is a clarification letter, and by the Ministry's own 2019 position such letters are not normative legal acts. But customs offices apply it now, and the Federal Customs Service commission has not closed the question, so contracts and invoices are best written to survive either reading.

7. Expert opinion

Yaroslav Loginov — expert in logistics and customs clearance with 40 years of experience.

“In my experience the problem almost never starts at the border — it starts in the invoice. A supplier issues one total for goods and delivery, the buyer pays it in two transfers weeks apart, and by the time the declaration is filed nobody can say cleanly which amount covered what. That is exactly the situation this letter turns into a customs value adjustment, and the cargo pays for it in storage days.”

“My advice to suppliers is unglamorous: fix the paperwork before the goods move. Split the invoices, write the payment terms in plain language, keep the value dates clean, and send your buyer the confirmations without being chased. Allow a few days in your planning for document questions during clearance — on split-payment contracts they now come more often than they used to.”

Summary

The February 2025 letter makes the timing of each payment part of the customs value calculation: amounts paid before the declaration is registered count as actually spent, amounts paid after release are converted at the declaration-date rate. The letter is not a normative act, but customs offices apply it and tend to choose the reading that produces the higher value. For an exporter this is a documentation task, not a legal one — split invoices, unambiguous payment terms, clean dates. Send us a request, and we will review your documents against your next shipment to Russia.