EAEU HS Code List and Russian Permit Rules: What Your Buyer Will Ask You For

23 September 2022Trade Pulse

Before your next consignment to Russia leaves the plant, find out which EAEU HS code your buyer will declare it under. The Russian Ministry of Industry and Trade has approved a list of products, identified by codes of the unified Commodity Nomenclature of Foreign Economic Activity of the Eurasian Economic Union, to which paragraph 6 of Annex 18 to Government Decree No. 353 of 12 March 2022 on the specifics of permitting activities in Russia does not apply (Order No. 3898 of 14 September 2022). For goods that fall inside that list the relaxed route to a permit document is closed, and conformity has to be confirmed the standard way. Most of the evidence for that standard route comes from the manufacturer, which means from you: technical file, samples, plant data. If it is not ready by the time the truck or container reaches the border, the cargo waits in a temporary storage warehouse, and that wait turns into a claim between you and your customer.

What the order actually changes for your shipment

The order bans nothing and changes no duty rates. It draws a line through the product range by HS code. On one side are goods for which the eased permitting regime introduced in 2022 can still be used. On the other side are the codes named in the list: for them the exemption in paragraph 6 of Annex 18 does not work, and the permit document has to be obtained under the ordinary conformity assessment procedure.

For you as the shipper the consequence is not legal but operational. The same product, the same plant, the same customer — but the set of papers your buyer asks for becomes heavier, and the lead time between the order and the ready-to-declare shipment becomes longer. Exporters usually notice the change late: the goods are already produced, the booking is made, and only then the importer reports that the previous document is no longer accepted for this code.

The HS code decides, not the product name

The list is written in codes, not in commercial descriptions. Whether your goods fall under the stricter route depends on the ten-digit EAEU code your buyer declares and on how Russian customs assesses that classification — not on how the product is named in your catalogue. Two items that look like one product family in your price list can sit in different codes and follow different permit routes.

This is why the exact code should be agreed with the buyer before production starts, and why your commercial documents must support it. The invoice and packing list should state material and composition, function and intended use, model and article number — enough detail for the importer and the customs broker to defend the code. Vague descriptions are the most common reason for a code being reassessed at the border, and a reassessed code can move the goods straight into the stricter list. If the code turns out to be inside it, the importer starts a full certification procedure, and the shipment can only be declared once the document is registered — this is the part of customs clearance in Russia where deliveries stall most often.

EAEU HS Code List and Russian Permit Rules: What Your Buyer Will Ask You For

Permit documents are checked by HS code: the cargo moves only when the paperwork matches the declared code.

What your Russian buyer will now request from you

The applicant for a Russian permit document must be a company registered in the Union, so the application itself is filed by your importer. But the substance of the file is yours. Expect requests for a technical description and specification, information on materials and composition, the standards your production follows, existing test reports, photographs of the product and its label, details of the manufacturing site, a letter authorising the importer to act on your behalf and, for series documents, your quality management certificate if you hold one. Samples are requested separately and go to an accredited laboratory in Russia — they normally travel by air ahead of the commercial batch, with their own invoice and marking, and their clearance follows the rules for samples and catalogues.

Point of difference	Code outside the list	Code inside the list
Route to the permit document	The eased 2022 regime may be used	Standard conformity assessment only
Input from the manufacturer	Technical description and contract documents	Full technical file, plant data, authorisation letter
Samples	Usually not shipped separately	Sent in advance for laboratory testing
Lead time before shipping	Days	Weeks: testing plus issue and registration
Risk at the border	Low	Cargo held until the document is registered

The permit document must exist and be registered before the goods are declared, not after they arrive. A document issued later than the arrival date will not release the cargo, and every day in the temporary storage warehouse is paid for — together with demurrage on the container or the truck.

Labelling belongs to the same package. Applying the conformity mark and the Russian-language product label at your plant is cheaper and faster than relabelling a pallet in a warehouse near the border, and it removes one more reason for the shipment to be stopped.

What the exporter should do before shipping

Ask the buyer for the exact ten-digit EAEU HS code for every item in the order, not one code for the whole invoice.
Have the buyer check those codes against the list approved by the order before you schedule production or book transport.
If a code is inside the list, assemble the technical file at once: specification, composition and materials, applied standards, existing test reports, label artwork, plant details.
Send samples early and separately from the commercial batch, with their own invoice, so laboratory testing runs in parallel with production.
Issue the authorisation letter for the importer and share your quality management certificate if the document is to cover serial production.
Agree who applies the conformity mark and the Russian label, and confirm the artwork before packing.
Keep the wording identical across the technical file, the invoice and the label: the same product name, model and article number.
Do not release the shipment until the buyer confirms in writing that the permit document is registered, and reflect that condition in the shipping schedule of your contract.

Frequently asked questions

Does this mean my product can no longer be sold in Russia?
No. The order does not prohibit anything. It defines the codes for which the eased permitting option is unavailable, so the goods are imported with a permit document obtained under the standard procedure.

Who applies for the document — the manufacturer or the buyer?
The applicant is a company registered in the Union, normally your importer. Your role is to supply the technical file, the samples and the authorisation letter without which the application cannot move.

How early should we start?
From the moment the contract is signed. Laboratory testing and issue of the document take weeks, not days, and that period runs before the goods may be declared, not while they are in transit.

What happens if the cargo arrives without the document?
It is not released. The consignment goes into a temporary storage warehouse until the paperwork is in place, storage and demurrage accrue daily, and in the worst case the goods are returned at the seller's expense.

Summary

The order fixes a list of EAEU codes for which the eased 2022 permitting route no longer applies, so goods with those codes need a permit document obtained under the standard procedure. For the shipper this changes the paperwork, not the market access: technical file, samples for testing, authorisation letter and correct labelling, all prepared before the goods move. Plan weeks, not days, and make the confirmed registration of the document a condition of dispatch. Request a consultation, and we will review the codes and permit documents for your specific shipment.

We will check your EAEU HS codes and the permit documents your shipment needs before it leaves the plant.

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