FTS register of customs representatives: how to check your buyer's broker and keep your shipment moving
When you ship to Russia, the customs declaration for your consignment is filed by a Russian company — your buyer, or, far more often, a customs representative acting on their behalf. That company's line in the FTS register is as much a shipping parameter as transit time or the duty rate. While it is listed, it may declare your cargo and dispose of advance payments under its agency contract; from the moment it is struck off, that right ends — and your container keeps standing at a temporary storage warehouse with the bill running. From 19 September 2026 a new procedure applies for how the Federal Customs Service excludes legal entities from the register of customs representatives, approved by order No. 474 of 29 May 2026; the previous procedure, approved by order No. 2037 of 13 December 2018, is repealed. Your export paperwork does not change. What changes is the probability that a buyer will need a complete, clean document set from you within hours.
What this means for your shipment
Formally the order is addressed to the customs service, not to business: it describes how customs authorities act when a legal entity is excluded from the register of customs representatives — from preparing the decision to communicating it and amending the register. It does not invent new grounds for exclusion; those are set by the law of the Eurasian Economic Union and the Russian law on customs regulation.
The consequences, however, land on the representative's client — and one link up the chain, on you. An agency contract with an excluded company stops working: it can no longer file a new declaration on your buyer's behalf, while goods that are at that moment sitting at a temporary storage warehouse or moving under the customs transit procedure remain the buyer's responsibility. Nothing is handed over to another representative automatically — a new contract, a new power of attorney and new authority all have to be arranged from scratch. For you that is a pause on the Russian side that your shipment cannot avoid, because the goods have already arrived.
Obligations under declarations already filed do not disappear when a company is struck off the register, but the right to file new ones ends immediately — and that is exactly where cargo stops: the consignment is at the warehouse, the payments have been made, and there is nobody left who may declare it.
The updated procedure is a good reason to ask your buyer one question before the next booking: who files the declaration for our goods, and is that company in the register today? The register is public, the check takes a couple of minutes, and for a supplier it is the cheapest way to find out whether the last leg of the delivery has a single point of failure.
Who actually declares your goods, and which register matters
In everyday speech people say «broker»; the EAEU Customs Code has no such term — it has the customs representative. This is a Russian legal entity included by the FTS in a special register, which performs customs operations in the name of and on the instruction of the declarant. What separates it from an ordinary intermediary is joint and several liability with the declarant for customs duties and taxes, and the security it has to provide to be entered in the register. That is also why a customs clearance company without a line in the register cannot sign the declaration for your buyer: at most it may prepare documents.
As a foreign supplier you cannot be the declarant in Russia yourself. The declarant is the Russian party to the contract — your buyer or the consignee — and everything filed at the border is filed in their name. Your leverage is therefore not the filing but the documents and the timing: what you send, how quickly, and how fast you can reissue it.
The FTS keeps several registers and they are easily confused. The register of customs representatives is about declaring. The register of customs carriers is about something else: it lists companies allowed to move goods under customs control in the transit procedure without separate security for each consignment. If your route runs from the port of arrival to an inland customs office, those two registers cover different legs of the chain, and exclusion from one does not affect status in the other. A third, independent status is the register of temporary storage warehouse owners. Whether the cargo comes by sea, by rail or by air, all three are worth checking before a large shipment: the carrier, the representative and the warehouse.
How the declaring process itself is organised, and at which steps time is most often lost, we covered in detail in «Customs clearance procedure: nuances and specifics». If your buyer is only choosing a contractor now, the simplest thing to ask for is the number of the certificate of inclusion in the register and a comparison with the public FTS data — in our experience of customs clearance, this is the cheapest check that exists.
Containers at a temporary storage warehouse: while no declaration is filed, storage is charged for every day.
Payments, storage and where the chain breaks
The most unpleasant part is money. Many importers transfer advance customs payments not to their own unified personal account with the FTS, but to the representative, who then pays on their behalf. The arrangement works exactly as long as the representative has authority. Whose personal account is used for each consignment therefore belongs in the buyer's contract — and for you it is also a delivery question: money frozen on the account of a company that has been struck off is money not available for the duty on the next declaration, and a buyer in that position slows down.
Ask your buyer whose personal account the customs payments run through: if the advances are sitting on the representative's account, they cannot be used without that company — while the customs fee and the duty on the next declaration still have to be paid on time, and it is your consignment that waits.
| Situation | What it means for your shipment | What the exporter does |
|---|---|---|
| The representative is struck off the register while the goods are still in transit | Nobody may file the declaration on arrival; demurrage and storage at the warehouse | Do not release originals or telex release until the buyer names the new representative; be ready to reissue documents to new details |
| The goods are already at the temporary storage warehouse, no declaration filed | Storage charged per day, risk that the temporary storage period expires | Send the full set of scans the same day and courier the originals; confirm that you can issue duplicates of the invoice, packing list and transport document |
| The declaration has been released, post-clearance control is under way | Customs asks the buyer to confirm the declared value, and the request comes back to you months later | Keep the export declaration, price lists, contract, payment confirmations and price correspondence for at least three years |
| Advance payments are held on the representative's account | The funds hang, the new filer does not see them, clearance is postponed | Expect a delay and agree in the contract who bears storage costs in such a case |
| The electronic signature and portal access are issued to the representative | The buyer has no access to their own declarations, so you cannot obtain copies either | Ask for copies of the filed declarations for your goods — they show the HS code and the value declared |
| Permits and certificates were arranged through the representative | A new filer starts the approvals from scratch, which adds weeks | Keep your own test reports and technical file so that certification can be reissued quickly |
A separate question is how long customs clearance takes when the contractor is changed mid-shipment. The declaration itself is released quickly if the set of documents is complete and correct, but drawing up a new contract and power of attorney and handing over the file easily eats several days — and those are exactly the days that are paid for as storage. Everything you can pre-position on your side comes straight off that interval. How we organise the work and what we take on when we join someone else's shipment halfway is described on the page «Why iCustoms»: in this situation help with customs clearance comes down to the speed of assembling the set.
What to do on the exporter's side
- Ask your buyer which company files the declaration for your goods, request the number of its certificate of inclusion in the register, and have it checked against the public FTS data — before 19 September 2026 and then routinely, before every large shipment.
- Keep a complete file for every consignment on your side as well: contract, commercial invoice, packing list, transport documents, certificate of origin, permits and the technical descriptions used for HS classification. If the Russian side has to change filer, this is the set that will be requested within hours.
- Agree in advance what you can reissue and how fast: a corrected invoice, a switch bill of lading, an amended consignee. That is your half of the contingency plan, and usually the half that decides the timing.
- Ask for copies of the customs declarations filed for your goods, with the HS code and the declared value. They protect you when post-clearance control comes back with questions a year later.
- Check in whose name the conformity certificates and declarations for your goods are issued, and keep the test reports and technical file yourself, so that approvals can be redone without repeating the whole procedure.
- Do not release originals or telex release until you know who will declare the goods on arrival — a container that arrives without a filer starts costing money on day one.
- Ask the buyer to keep a framework contract with a second customs representative, and to check the status of the carrier and the temporary storage warehouse in their own registers: the chain breaks at any link.
Frequently asked questions
Our buyer's customs representative has been struck off the register — are the declarations already released cancelled?
No. Released declarations remain valid and the goods stay under the declared procedure. What ends is the company's right to perform new customs operations on the declarant's behalf; the obligation to pay charges and the responsibility for the accuracy of the information declared on past shipments stay in place.
Can we declare the goods ourselves, as the foreign supplier?
No. The declarant is a Russian entity — normally your buyer. They may file on their own, which requires an electronic signature, access to the foreign trade participant's personal cabinet, their own personal account for duties and customs fees, and a specialist who will get the HS code and the customs value right — or they may engage a customs representative from the register.
Where can we see whether a company is in the register?
The FTS maintains and publishes the registers of customs representatives, customs carriers and temporary storage warehouse owners openly. Check not only the name but also the tax number (INN) and the certificate number: different legal entities with similar names are common.
Does anything have to be done before 19 September 2026?
The order requires no special action from business — it governs the work of the customs authorities. The sensible minimum for an exporter: know who files declarations for your goods, confirm that the company is currently in the register, and make sure your own document set is complete and can be reissued quickly.
Who pays for storage while the Russian side arranges a new representative?
That depends on the delivery terms in your contract. Where the buyer takes the goods at the port or the border, the cost is theirs; where you deliver to their door, it lands on you. Worth settling in the contract before the situation arises rather than after.
Summary
From 19 September 2026 an updated FTS procedure applies for excluding legal entities from the register of customs representatives, approved by order No. 474 of 29 May 2026 in place of order No. 2037 of 13 December 2018. The document is addressed to the customs authorities, but the price of the question is measured in days of standstill and storage charges at the Russian end of your route. Ask who declares your goods, check that company in the public register before every large shipment, keep a complete and reissuable document set on your side, and make sure the buyer has a fallback contractor. Request a consultation and we will go through your specific shipment.
We will take over customs clearance of your consignment in Russia if your buyer's current representative runs into trouble.
Read also:
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- Customs Clearance and Freight Logistics for Exporters: What Your Russian Buyer Will Ask You For
- Poultry products from Spain: what your Russian buyer will now require from your shipment
- Russian Export Duty on Sunflower Oil and Meal: How the Rate Is Calculated and Why the Declaration Date Decides Your Price
