Lead and lead scrap under HS 7801 and 7802: Russia's one-off export licence, documents and shipping timelines

What exactly falls under the permit regime

The restriction is built on customs codes, not on commercial product names, so the first thing to do is to look again at how your material is classified in the Russian declaration — not at how it is called in your purchase order. Two groups are covered.

• Code 7802 00 000 0 — lead waste and scrap. This is battery scrap, power cable sheathing, sheet and pipe offcuts, spent plates and grids, off-specification and defective articles going for remelting.
• Heading 7801 — unwrought lead and alloys containing it: refined lead ingots and pigs, antimonial and other lead-based alloys in primary form.

The single carve-out is for semi-products of non-ferrous metal production containing precious metals under code 7801 99 100 0. The exemption is narrow and is not confirmed by a simple declaration in the paperwork: a documentary description of the composition is required — a test report, an assay certificate or a batch passport from the producer. If the composition is not evidenced, for customs purposes the goods remain ordinary lead of heading 7801, with every requirement that follows.

The carve-out is written around the composition of the goods, not around the code as a whole: putting code 7801 99 100 0 in the declaration does not in itself free the consignment from the licence. Until the semi-product status and the precious-metal content are documented, the inspector will wait for the permit.

Check the borderline cases separately, because they usually appear in the commercial documents you issue. Lead pigs remelted from scrap are already 7801 and no longer 7802 — but the licence is required in both cases, so an error in the code will not "rescue" the shipment from the permit regime. What it will do is change the list of supporting documents and create a discrepancy between the declaration and the licence, and that is the shortest route to a refusal of release. If your order confirmation says "lead scrap" while the specification annexed to the contract says "refined lead ingots", the mismatch will surface at the licence stage — and will be your delay too.

The one-off licence and what it fixes in your contract

Licences for participants of foreign economic activity are issued by Minpromtorg. A one-off licence is a document tied to one specific transaction: it is issued for one type of goods under one foreign trade contract, stating quantity, value and country of destination. The practical consequences for you are direct — every new contract and every new destination needs its own licence, and the quantity on an issued licence cannot be increased: a new one has to be obtained.

The application is accompanied by the foreign trade contract with its specifications and by documents evidencing lawful ownership of the goods and their origin. For scrap this is especially sensitive: acceptance and handover certificates, purchase agreements, documents on how the waste arose at the seller's own production. This is exactly the block where time is normally lost, and part of it depends on you: the signed contract and the agreed specification must exist before the application goes in. A contract with quantity or value left "to be agreed later" is not a basis for a licence.

The licence then has to reach the customs procedure itself. It is registered for control with the customs authority, its details are stated in the declaration box for permit documents, and the quantity is written off against the licence at every release. If the contract is performed in instalments, keep your own record of the balance: once the licensed quantity is used up, the next lot will not move even if the vessel is booked and the truck is at the gate.

The measure runs for six months from the date the decree entered into force. That means contracts with shipments falling inside this window have to be re-planned now, on the calendar, rather than at the moment the cargo becomes ready.

What this means for your shipment: documents, timing, delay risk

The licence supplements the usual export file, it does not replace it. The base set on the Russian side still includes the foreign trade contract with specifications and annexes, the invoice, the packing list, transport documents according to the mode of carriage (CMR, rail waybill, bill of lading), documents on the origin and acquisition of the goods, and confirmation that the contract is registered with the authorised bank where the amount exceeds the registration threshold. For non-ferrous scrap, permits for the activity itself are added — collection, storage, processing and sale of scrap. All of this must be in the hands of the declarant or the customs clearance provider before the declaration is filed, not on the day release is expected.

Your part of the package is small but blocking. Expect your Russian counterparty to come back to you for: a signed contract and specification with an exact description of the goods, the unit of measure, the quantity and the value; a fixed country of destination; commercial documents (order, invoice, packing list) that repeat the same wording and the same units as the specification; and, where the carve-out is claimed, the test report or assay certificate on the composition. Any amendment you sign late — a changed quantity, a new delivery address, another destination — restarts the permit stage rather than adjusting it.

On timing, plan two stages instead of one: preparation and processing of the licence application, and then registration of the licence for control and its correct reflection in the declaration. Only after the second stage does a transport booking become realistic. This applies to every mode: sea freight, rail transport and road groupage are all released against the same declaration.

The delay risk is concrete and mostly lands on the party that booked the transport. Without the licence the goods are not released, the consignment stays on the yard or in the terminal, and you get truck standing time, demurrage and detention on a sea shipment, and a broken delivery schedule to your own customers. Under EXW and FCA terms these costs are yours, even though the permit is not something you can obtain: the licence is applied for by the owner of the goods on the Russian side, and no Incoterm transfers that step to a foreign buyer. Your counterparty has its own reason to push for date changes — the release date starts its clock for confirming the zero-rated export and for closing the contract with its bank.

Destinations deserve a separate look, because the measure is about goods leaving Russia — not about goods arriving in your country specifically. A delivery to a CIS country outside the EAEU, Uzbekistan being the usual example, is handled in the ordinary way: a declaration is filed and actual export is confirmed on the basis of the declaration bearing customs marks and the transport documents; carriage by road or rail across Kazakhstan adds transit formalities on top. If the shipment goes to an EAEU country, where there is no customs declaring, the position on applying the permit regime should be clarified before the contract is signed — this is the case where a written clarification obtained in advance is far cheaper than a stopped consignment. If your material also needs conformity documents on the import leg, plan that in parallel through certification, and treat the whole chain as one schedule via end-to-end logistics and customs clearance.

A broker in the customs register is not an export permit

These two things are constantly confused, and the confusion is expensive. A "customs licence" in the sense of a permit to take specific goods out of the country is the Minpromtorg document: it is issued to the owner of the goods for a particular transaction. A "customs broker licence" or "customs representative licence" is colloquial wording for a completely different status — the company's inclusion in the register of customs representatives kept by the Russian Federal Customs Service. There is no separate document called a licence there; there is a certificate of inclusion in the register, security for the performance of obligations and liability insurance.

So when your Russian partner says the shipment is handled by a licensed broker, that answers a different question. Register status allows the representative to file the declaration on the declarant's behalf; it gives nobody the right to take lead out of the country without the permit document. Ask for the licence number and confirmation that it has been registered for control — not for the broker's credentials.

What to do now

1. List every flow under your contracts where lead physically leaves Russia — purchases of ingots and alloys, buy-back of battery scrap, returns of your own material after processing, re-export of unsold stock — and check the codes: anything falling under 7801 or 7802 00 000 0 now moves only against a licence.
2. Check whether your material is the carve-out from code 7801 99 100 0 and, if it is, obtain documentary proof of composition from the producer: test report, assay certificate, batch passport.
3. Map your delivery schedule against the six-month window of the measure and re-agree shipping dates with your counterparty before booking transport.
4. Send a clean contract package: signed contract with specification, exact description of the goods, unit of measure, quantity, value and country of destination — with nothing left open.
5. Make sure the licence application goes in before the cargo is ready, not after: ask for the filing date and keep it in your own delivery plan.
6. Ask for confirmation that the licence has been issued and registered for control with customs, and for its details, before the declaration is filed.
7. Keep your own running balance of the licensed quantity if you take the contract in instalments, and trigger the next licence in advance rather than on the last lot.
8. Cross-check your invoice and packing list against the specification — description, units, quantity — so that the declaration and the licence match to the letter.

Frequently asked questions

Is the decree already in force?
Yes. It entered into force on 2 September 2026 and runs for six months from that date. Shipments you planned for the coming weeks already require a licence.

Can we obtain the licence ourselves as the foreign buyer?
No. The licence is issued to the owner of the goods, the party to the contract on the Russian side, for a specific transaction. Your role is to provide the contract, the specification and the composition documents fast enough for the application to be filed.

Is a licence needed for every consignment?
A one-off licence is issued against a specific contract with a stated quantity and value. Shipments can be made in instalments until the stated quantity is exhausted; a new contract or a different country of destination requires a separate licence.

Our cargo goes to Uzbekistan, not to our own country — does this concern us?
Yes. The measure applies to goods leaving Russia, whatever the destination. A delivery to a CIS country outside the EAEU is declared in the ordinary way with confirmation of actual export, and carriage across Kazakhstan adds transit formalities.

Is lead part of Russia's traceability regime for goods?
No, these are different mechanisms. Traceability works from its own closed list of goods and has nothing to do with headings 7801 and 7802. The export permit regime is established by a separate decision and is evidenced by the licence.

What happens if the declaration is filed without the licence?
The goods are not released: the permit document is a condition for placing goods under the customs procedure. The consignment stays where it is, and you get transport standing time, demurrage risk on a sea shipment and a shifted delivery date down your whole chain.

Summary

From 2 September 2026 lead, lead alloys and lead scrap under headings 7801 and 7802 00 000 0 may leave Russia only against a one-off Minpromtorg licence, and the measure is set for six months. The only exclusion is semi-products of non-ferrous metal production containing precious metals under code 7801 99 100 0, and that has to be proven by the composition of the goods. For you as the foreign counterparty the real risk is not the licence but the calendar: it has to be obtained and registered for control before the declaration is filed, otherwise the shipment stops and the standing costs are yours. Request a consultation and we will go through your specific cargo and route.

We will check your goods against HS 7801 and 7802, help your Russian counterparty assemble the one-off licence package and handle the export declaration and delivery by sea, rail or road.

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