Exporting to Russia from 1 September 2026: the permit documents your buyer will ask you for before shipment

What changed in the permit rules

1 September 2026 brought several unrelated changes at once. For you as the shipper they add up to a single question: which of your product lines can still be cleared by your Russian buyer on somebody else's conformity document, and which now need a document of their own — with your samples and your technical file. In short:

• the special provisions of Decree No. 353 have largely been extended to 1 September 2027;
• the transition period ended for part of the documents issued under Decree No. 2425;
• the special import procedure for certain goods from EAEU states expired;
• for products on Ministry of Industry and Trade List No. 4114 additional restrictions apply to the relaxations of Decree No. 353;
• six marking pilot schemes for individual industrial goods were completed;
• new certification rules for transport security equipment came into force;
• Rosstandart received federal state control powers over certain types of industrial products;
• amendments to TR CU 010/2011 "On the safety of machinery and equipment" took effect;
• GOST R 72756-2026 came into force for toys with artificial intelligence technologies;
• general-purpose electric motors rated 1–400 kW were added to the mandatory certification list, with a transition period.

The risk here is not the rules themselves but inertia: the contract was signed in spring, the conformity assessment route was agreed at the same time, and the cargo arrives in autumn — by the time the declaration is filed, the document that looked workable no longer covers the item.

Decree No. 353: letter of authorization to use your certificate and List No. 4114

Decree No. 353 remains the fastest route into Russia for many buyers: the goods are imported under a conformity document issued not to the importer but to another applicant — the manufacturer or another holder. That other holder is very often you. The basis for using it is the holder's written consent: a letter of authorization to use the certificate, or a permission to use the certificate of conformity issued in the name of the importing company. The extension to 1 September 2027 means the route is alive for another year — but as an exception, not as the norm. In practice this is the document your Russian buyer will ask you for, in their company name, before the declaration is filed.

The decisive fork is List No. 4114. If your product range falls under it, the relaxations of Decree No. 353 apply with additional restrictions, and your buyer can no longer rely on your certificate by default. The practical sequence for the shipment is: first match the goods against the list, then decide whether the import runs on your document or on a certificate issued to the importer. Issuing certificates and declarations of conformity in the importer's name takes time for testing and registration — and it needs samples and a technical file from you. That clock has to start before the vessel sails, not after it berths.

A letter of authorization does not cure a defect in the certificate itself: if the certificate covers a different model, a different manufacturer or a different production address, Russian customs will refuse release no matter how correctly the holder's consent is drafted. Any change of factory, production site or model designation on your side has to reach the buyer before the goods are loaded.

Permit documents for shipments to Russia: what changed on 1 September 2026

Marking, machinery and electric motors: whose shipments are affected

The six completed marking pilots cover very specific product lines: certain fibre-optic products, heating appliances, cable and wire products, certain pyrotechnics and fire-extinguishing equipment, polymer pipe products and the raw materials used to make them, and certain vehicle components, devices with internal combustion engines and self-propelled machinery. Completion of a pilot is the stage after which the question of mandatory requirements is decided — so if you ship any of these groups, look now at where the codes would physically be applied: on your production line, at a warehouse abroad, or after arrival in Russia. Each option lands differently on your packing, your labelling artwork and your lead time, and buyers increasingly ask the supplier to apply codes at source.

The second large group is machinery and equipment. The amendments to TR CU 010/2011 affect machine tools, production lines, pumping and lifting equipment: they change the requirements against which the evidence base and the technical documentation are assembled — and that documentation comes from the manufacturer, which means from you. General-purpose electric motors rated 1–400 kW deserve a separate mention: they have been added to the mandatory certification list, although a transition period applies. This concerns not only motors shipped as goods in their own right, but also complete units where the motor forms part of a machine. In customs clearance of equipment and machine tools such assemblies are frequently declared as separate line items, and each needs its own permit documents.

Two narrower but sensitive changes complete the picture: new certification rules for transport security equipment, and GOST R 72756-2026 for toys with artificial intelligence technologies. The latter is a direct signal for anyone shipping consumer electronics for children — interactive toys with voice assistants and learning functions are now assessed against a dedicated standard.

Before and after: what it means for your shipment

Note the last row: control over industrial products does not end when the declaration is released. A document issued as a formality can resurface once the goods are already circulating on the market — and the questions then go back up the chain to the manufacturer.

What the exporter should do

1. Send your buyer an item-level list of what ships in the next three months: model and modification designations, manufacturer name, production site addresses and the HS codes you expect to be declared. The work is done position by position, not contract by contract.
2. Ask the buyer to match that list against Ministry of Industry and Trade List No. 4114. This is the first filter: it decides whether the relaxations of Decree No. 353 are available for your goods at all.
3. If you hold the conformity document, check its scope yourself before it is quoted in the declaration: product name, manufacturer, production sites, validity period and assessment scheme must cover exactly what is being loaded.
4. If the import runs on your document, issue the letter of authorization to use the certificate — or the permission to use the certificate of conformity — in the importing company's name, current and covering precisely the products being declared.
5. For documents issued under Decree No. 2425, confirm with the buyer whether they fall into the part whose transition period has now closed. If they do, the replacement has to be issued before the next shipment, not after arrival.
6. If any part of the consignment moves from or through EAEU states under the former special procedure, rebuild the conformity route under the general rules — the old mechanism no longer applies.
7. For machinery, equipment and electric motors, start the paperwork early on your side: samples for testing and the manufacturer's technical documentation are the long pole. Testing and registration take weeks, and this is the single most common source of demurrage and storage charges.
8. Where classification is arguable, let the buyer close it in advance through an advance customs classification ruling, and verify lists, registers and document formats against official Russian sources rather than against copies circulating between suppliers.

Frequently asked questions

Our Russian buyer asks for a "letter of authorization to use the certificate". What is it?
It is your written consent, as the holder of a conformity document, to that document being used for import by a named company. It is issued in the importer's name and lets the goods be cleared under a certificate that was issued to you, not to them.

Does that mechanism still work after 1 September 2026?
Yes — the provisions of Decree No. 353 have largely been extended to 1 September 2027. But for products on List No. 4114 the relaxations are restricted, so the goods are checked first and the document second.

How is a permission to use a certificate different from the buyer holding their own certificate?
Their own document is issued to them as the applicant, on the basis of testing. A permission or letter of authorization is only the holder's consent to use an existing document at import. It does not widen the certificate's scope and does not replace it.

We moved production to another plant and changed the model index. Does that matter?
Yes, and it is the most expensive detail to discover late. If the production address, manufacturer or modification in the certificate differs from the shipping documents, customs will refuse release even though the consent paperwork is flawless. Tell the buyer before loading.

We ship equipment with built-in electric motors. Are we affected?
Yes, if a motor rated 1–400 kW is declared as a separate line item or supplied as a standalone product. A transition period applies, and it is there to prepare in — samples, testing and documentation — not to wait out.

Summary

From 1 September 2026 the permit side of importing into Russia changed on several fronts at once: the provisions of Decree No. 353 were extended, conditions tightened for List No. 4114, the transition period closed for part of the Decree No. 2425 documents, and the special import procedure for certain goods from EAEU states ended. Machinery and equipment, electric motors of 1–400 kW, transport security equipment and six industrial groups whose marking pilots have finished are affected separately. For the exporter the practical rule is unchanged: documents are checked item by item and before loading — reissuing them while the container sits at a temporary storage warehouse costs several times more. Request a consultation and we will go through your specific consignment.

We will review the permit documents for your shipment to Russia and tell you exactly what your buyer needs from you before loading.

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