DT: The EEC proposes specifying the Kazakhstan product catalog code and the code for products exempt from Russian Federation labeling requirements

What is this draft and what stage is it at?

The draft decision of the EEC Board amends paragraph 15 of the Procedure for Filling Out the Goods Declaration, approved by Decision No. 257 of the Customs Union Commission dated May 20, 2010. It is this paragraph that specifies what information must be entered in the DT fields. The basis for the changes is Paragraph 5 of Article 105 of the EAEU Customs Code, which elevates the procedure for completing the declaration to the supranational level.

The public consultation took place from September 1 to October 1, 2026; on the EEC portal, this stage is marked as “Consultation Completed.” As of the date of publication, we have not found the adopted decision, so we consider this to be a draft. The draft itself specifies that it will take effect on October 1, 2027. It was prepared in response to requests from the Ministry of Finance and the State Revenue Committee of Kazakhstan, as well as the Ministry of Economic Development of Russia, and was reviewed during three meetings of the working group on customs declarations.

Kazakhstan: National Catalog Code in Field 31

Effective January 1, 2026, Kazakhstan’s Law “On the Regulation of Trade Activities” requires that imported goods be registered in the National Catalog of Goods prior to their sale. According to the EEC’s guidance, the current procedure does not specify where in the customs declaration to indicate the code from this catalog. As a result, customs authorities may request additional documents, which delays the release of goods.

The draft fills this gap: a separate field will be added to the goods description (Field 31) to enter the National Catalog code used in Kazakhstan. If the code is entered in the customs declaration immediately, there is no need to submit it separately upon request.

For importers into Kazakhstan, this means one simple thing: a product entry in the catalog must be created before submitting the customs declaration; otherwise, there will be nothing to enter for the new number.

Russia: Codes for Exempted Goods in Column 33

The Russian list of goods subject to mandatory labeling is defined by HS codes and descriptions. According to the EEC reference, there may be exceptions within the same code: different packaging or repackaging, a different intended use (e.g., products for children under three years of age or dietary foods), different implementation dates for labeling, the presence of a state registration certificate, and artisan products. The EEC refers to such items as “exemption goods.”

The current Procedure does not allow for the automatic distinction between goods that must be labeled and those that fall under the exemption, even though they share the same HS code. The draft adds the option to specify in column 33 the code from the classifier used in Russia for information on goods not included in the list of specific goods subject to mandatory labeling. According to the explanatory note, the goal is to automate the classification of goods as subject to or exempt from labeling and to expedite customs clearance.

If your product is subject to labeling, the release process remains the same: we covered identification codes and system tracking in our materials on “Honest ZNAK” labeling for shipments from China and the labeling of children’s toys.

What the draft does not change

• The list of goods subject to labeling and the deadlines for implementing labeling: these are determined by national laws and regulations, not by the Procedure for Filling Out the DT.
• Procedure for registering goods in the National Catalog of Kazakhstan: the draft merely specifies where to enter a code that has already been received.
• Other Union countries: According to the EEC’s report, no similar requirements have been introduced in the three other member states.

According to the EEC’s assessment, the draft does not impose additional costs on businesses and has no negative impact: it allows information to be entered into the DT immediately. The conclusion on the regulatory impact assessment, according to the reference, will be presented after the draft is reviewed.

What Importers and Customs Representatives Should Do

1. For shipments to Kazakhstan, ensure that goods are registered in the National Catalog prior to sale, and keep the catalog code along with the product description in the product listing.
2. For shipments to Russia, categorize the product list into those subject to labeling requirements and those subject to exemptions based on description, intended use, packaging, and the presence of a state registration certificate.
3. Create fields in the product catalog for both codes so you don’t have to enter them manually for each shipment later.
4. Ask your customs representative or software developer how they plan to transmit the new information to the Customs Terminal: the deadline of October 2027 is sufficient, but integrations should be prepared in advance.
5. Until the draft is adopted, process shipments according to current rules: if customs requests a catalog code or confirmation of withdrawal, respond with the necessary documents as before. No changes need to be made to the DT.
6. Monitor the project’s status on the EEC portal: both the text and the deadline may change following review.

We will verify how your goods are described in the declaration as part of the customs clearance process, and we monitor the validity of dates and labeling requirements in the “Foreign Economic Activity Pulse” section.

Frequently Asked Questions

Is this already in effect?
No. This is a draft decision by the EEC Board: the discussion concluded on October 1, 2026. The draft text proposes that it take effect on October 1, 2027.

Is it necessary to specify the Kazakhstan catalog code when importing into Russia?
No. The National Catalog number is designated for Kazakhstan, while the classification code for exempt goods is designated for Russia.

Will the code in column 33 be mandatory?
The EEC guidance refers to the “possibility of indicating” this information. Whether the indication is mandatory in specific cases will be determined by the adopted version of the regulation and national legislation.

What are exempt goods?
This is how the EEC guidance refers to goods with a HS code from the list of goods subject to labeling but falling under exceptions: for example, special packaging, products intended for children or dietary purposes, and artisanal products.

Will business costs increase?
According to the EEC’s assessment, no. However, you will need to prepare the data and update your software.