List No. 4114 extended to 1 September 2027: the conformity documents your Russian buyer will need before your goods can be declared

What the extension means for your shipment

Russian Government Decree No. 353 of 12.03.2022 sets out special rules for permit documents — relaxations that a large share of imports into Russia currently rely on. Order No. 4114 of the Ministry of Industry and Trade carves out a defined list of products, identified by EAEU HS codes, to which those relaxations do not apply. The extension to 1 September 2027 means the regime will not soften for another year, so no shipment plan for these goods should be built around a simplified confirmation of conformity.

The consequence lands on your side of the deal. A conformity document issued under the general rules requires laboratory testing and, in many cases, the import of samples — that is a separate small consignment with its own transport time and its own paperwork, and the request for it comes to the manufacturer. Your buyer can no longer let the conformity document catch up with the cargo: without a valid document the customs declaration will not pass the format and logic check, and the consignment stops at the border.

Note the effective date: 31 August 2026. Consignments already in transit have to be checked against the list under the new expiry date now, not when the vehicle or container reaches the customs control zone. If your goods are moving by sea or by rail, the transit time is exactly the window in which the document should have been under way.

The HS code decides, not the product name

The list is built on EAEU HS codes, not on product names. Whether your goods fall into the exceptions is therefore decided by the correctly determined code and by the technical characteristics — not by the description you put on the invoice and not by your own product category. The list covers, among other items, pyrotechnic articles, agricultural machinery, lifts and their parts, explosives, tractors and trailers, seat belts, weapons and ammunition, central heating radiators and heating convectors, polyethylene pipes for gaseous fuels, baby soothers, baby diapers, children's toothbrushes, children's underwear and footwear, toys for children under 14, prams and children's bicycles, metalworking machine tools, individual tooling such as circular saws and grinding wheels, child car seats and fire detectors.

The most common mistake is checking only the main product against the list. Components and spare parts have HS codes of their own: lift parts, seat belts and machine tool accessories require their own conformity documents even when they travel inside one shipment of equipment.

Mixed consignments and machinery shipped knocked-down deserve particular care. Where an invoice line simply reads "equipment", the buyer's broker has to open the packing list to see what is actually inside, and every model designation you left vague becomes a query at the border. If you ship production lines or machine tools, the practical fix is to give a line-by-line specification with model and type designations from the start — see how such consignments are handled in customs clearance of machinery and machine tools. Where the goods are on the list, the documents have to be prepared under the general certification rules.

Simplified route or general route: what to do in each case

The decision tree below is the one to run through for each specific consignment before it leaves your warehouse.

The exemption line is not an afterthought: a large share of disputed situations is resolved precisely by confirming that conformity assessment is not required. That confirmation is issued in Russia on the basis of the technical data you supply, which is why an incomplete product description on your side turns into a delay on the buyer's side.

EAEU technical regulations: what to check besides the list

List No. 4114 answers one question only: whether the simplifications apply. It does not remove the underlying requirements. Which document your product actually needs is determined by the EAEU technical regulations and by the lists of products subject to mandatory conformity assessment, historically introduced by decisions of the Customs Union Commission and updated by supranational acts. The check therefore runs in two steps: first, is a document needed and which one; second, may it be obtained in the simplified form.

These are union-level requirements, not Russian ones alone — the same technical regulations govern your deliveries to the other member states of the Eurasian Economic Union, so the work done once for a Russian consignee is not wasted on the next destination in the region. The practical conclusion for the exporter is simple: if your code is on the exceptions list, the answer to the second question is "no", and the whole delivery schedule is built around the lead times of the testing laboratory and the certification body. For a product group that is new to you, add a buffer — clearance time depends not on how fast the inspector works, but on whether the conformity document was ready when the cargo arrived. On long routes such as sea freight or rail transport that buffer is the transit time itself, and it is only useful if the procedure started before loading.

What the shipper should do

1. Ask your Russian buyer which EAEU HS code will be declared for every line of your proforma, including components, spare parts and tooling.
2. Have those codes checked against List No. 4114 and record which lines lose the simplifications until 1 September 2027.
3. For the listed lines, find out which technical regulation applies and which form of confirmation is required — a certificate or a declaration of conformity.
4. Assemble the technical file in advance: drawings, product descriptions, materials and composition, model and type designations, and any test reports you already hold.
5. Clarify early whether samples will be needed. Their import is a separate consignment with its own documents and its own transit time — see customs clearance of samples and catalogues.
6. Build the laboratory lead time into your production and shipping schedule, not into the arrival schedule.
7. Keep the wording identical everywhere: the product name and model in the conformity document must match your invoice and packing list exactly, because discrepancies are a standard reason for customs queries.
8. For lines that need no conformity assessment, give the buyer enough technical data to obtain an exemption letter before the declaration is filed.
9. Settle in the contract who pays for testing, samples and possible storage, and under which Incoterms the demurrage risk sits — this is where the cost of a missing document actually falls.

Frequently asked questions

Our product is on List No. 4114 — does that mean it cannot be shipped to Russia?
It can. The list does not prohibit import; it only excludes the special rules for permit documents under Decree No. 353. The documents are issued under the general rules of conformity confirmation.

What changed on 31 August 2026?
That is the date the order extending the list takes effect. The product scope and the logic are unchanged — only the expiry date moved, to 1 September 2027.

We ship a machine tool with circular saws and grinding wheels in the crate. Do those need checking as well?
Yes. These items appear in the list separately, and because they have their own HS codes they carry their own documentary requirements, regardless of the fact that they travel with the main machine.

What exactly will our buyer ask us for?
Technical documentation on the product and, in many cases, samples for laboratory testing. The samples move as a separate shipment with their own clearance, so the earlier the request is answered, the less it costs both sides.

Can the document be obtained once the goods have arrived?
Technically yes, but it almost always means demurrage: the consignment waits at a temporary storage warehouse while storage charges accumulate. Starting the procedure before loading is cheaper, which is why it helps when one broker handles certification and customs clearance in parallel.

Expert opinion

Yaroslav Loginov — expert in logistics and customs clearance with 40 years of experience.

«The mistake I see more often than any other looks harmless: the list is checked against the product name instead of the code. The supplier writes ‘equipment' on the invoice, and inside there are lift parts, seat belts or children's goods, each with its own code and its own requirements. It surfaces when the declaration is being prepared — too late to change anything, because the cargo is already at sea or on rail and cannot be stopped».

«The second point is timing. Testing and registration of the document take weeks, and no arrangement with an inspector shortens that. The sensible horizon is to start the conformity procedure when the order is placed with the manufacturer, not after shipment. If the product group is new to your buyer, add a buffer for the samples: that is a separate delivery with its own logistics and its own documents».

Summary

List No. 4114 of the Russian Ministry of Industry and Trade has been extended to 1 September 2027, and for the products it covers the relaxations of Decree No. 353 still do not apply. Membership of the list is decided by EAEU HS codes, line by line across the whole specification, components included. The conformity document must be ready before the customs declaration is filed, otherwise the consignment sits at a temporary storage warehouse at someone's expense. Send us a request and we will go through your specific shipment with you.