Marking of sanitary and hygiene products in Russia: what your buyer will need from you before the codes go on the packaging
Two decisions taken on your buyer's side now reach back to your production line: who orders the marking codes, and at which point they end up on the packaging — at your factory, at a consolidation warehouse abroad, or already in Russia under customs control. From 1 September registration in «Chestny Znak», the Russian national traceability system, and ordering codes for this product group become mandatory; from 1 October the codes must physically be on the pack. For a cross-border deal this is a new point of failure: a consignment can be fully ready for declaration, with duties and VAT paid, and still be barred from circulation because the codes are missing. Registration, describing every item in the National Catalogue, issuing and printing the codes — that is weeks of work, not a couple of days before the container arrives.
What changes on the buyer's side — and why it reaches your factory
Mandatory marking is introduced in two steps. The first is 1 September: the participant of turnover registers in the system and orders the codes. The second is 1 October: applying the codes to the packaging becomes mandatory. The one-month gap looks like a buffer, but for import it is eaten by transit — goods dispatched in September arrive in Russia when the application requirement is already in force. In practice, the order you are quoting today is one of the first that has to be shipped under the new rules.
The voluntary stage ran from September 2025, and the figures show the scale of the preparation: over 640 companies registered in the system, more than 10 thousand new goods were added to the National Catalogue, over 217 million marking codes were ordered, and 288 organisations took part in the testing — from large manufacturers to regional factories. The full ban on the circulation of unmarked sanitary and hygiene products takes effect on 1 October 2027; from the same date the transfer of sales data through online cash registers and work in electronic document exchange also become mandatory.
The practical meaning for a shipper is that the chain of obligations starts before the shipment. Codes are ordered against specific product items, which means that by the time the purchase order is placed your buyer must already know the exact range, the pack configuration and the characteristics of every unit — and all of that data comes from you. A change of bottle volume, formulation or units per carton made after the codes are ordered turns into a mismatch that is discovered when the goods are already in Russia.
Where the codes are applied: your plant or a warehouse in Russia
Technically there are two options. The first is marking at the production side: the codes are generated in the system by the importer, handed over to the factory or to the consolidation warehouse, applied to the packaging there, and the goods arrive in Russia ready for circulation. The second is application on Russian territory before release for free circulation — at a temporary storage warehouse or a customs warehouse.
The first option is usually cheaper per operation and creates no idle time after arrival, but it requires discipline from the supplier: codes must not be lost, duplicated or stuck «roughly in the right place». Each code identifies one single unit of goods, so a mixed-up roll of labels cannot be corrected on the line afterwards. The second option is more expensive because of the warehouse handling and the extra days, and that cost lands in the landed price of your goods — and, sooner or later, in the price negotiation with you.
If the codes are not applied before the goods are released for free circulation, the consignment has to be marked under customs control — extra days at the warehouse, paid handling operations, and a delivery date your buyer will miss. For the shipper this comes back as a claim, a delayed payment or tougher terms on the next order.
A separate point: marking at the factory requires the product description in the National Catalogue to match what is actually inside the carton. A discrepancy in volume, in the number of pieces per pack or in the brand name surfaces at the moment the goods are entered into circulation, and by then the container has already been discharged and every day of storage is billed. Anything you change on the line — a new pack size, an updated brand line, a promo bundle — has to reach the buyer before the codes are ordered, not with the shipping documents. Clearance of this kind of cargo, including the cosmetics and personal care range, is handled on the consignee's side — see customs clearance of cosmetics and customs clearance of goods.
Sanitary and hygiene products shipped to Russia: from 1 October the marking code must already be on the pack
Permit documents and the label
The marking code does not replace permit documents. Sanitary and hygiene products are imported with proof of conformity, and part of the range also with sanitary and epidemiological documents. What exactly is required is determined by the HS code and the composition of the product, so classification should be closed before shipment — and it is closed on the basis of your technical data: composition, purpose, intended user, test reports. Most delays at this stage are not caused by a slow buyer; they are caused by a specification or a formulation breakdown that arrives from the manufacturer a month later than asked. We prepare these documents ourselves as part of the certification service.
The second typical mistake is the label. The pack has to carry the marking code, the mandatory consumer information in Russian and the single EAC conformity mark, all at once. Suppliers often start looking for an «EAC label template» after half a million packs have already been printed with no physical space left for the code. The artwork is approved before the print run — together with the size and position of the field for the code and the method of application, direct print on the pack or a sticker. Reserving that field in the current artwork revision costs nothing; adding it to printed stock means re-labelling.
Dates and deadlines: what each one means for the shipper
| Date | What becomes mandatory in Russia | What it means for you as the shipper |
|---|---|---|
| Before 1 September | Nothing, participation is voluntary | Send the buyer full specifications for every item: name, brand, volume, units in the consumer and transport pack |
| From 1 September | Registration in the system and ordering of codes | Agree the label artwork and the point of application, reserve the field for the code in the next print run |
| From 1 October | Codes must be applied to the packaging | Either apply the codes at the plant or ship knowing the buyer will mark the goods in Russia before release — with the extra days and cost that implies |
| From 1 October 2027 | Full ban on circulation of unmarked products, online cash registers, electronic document exchange | Expect marked goods to be a condition of every order and document exchange with the buyer to move fully electronic |
The table shows the main thing: the obligations are spread over time, but the most labour-intensive part — describing the goods and setting up the application process — falls right at the beginning, when there is still no formal requirement. That is why requests for specifications and artwork are reaching you now, ahead of the dates in the table.
What to do as the exporter
- Confirm with the buyer which of your items fall into the sanitary and hygiene group under the Russian HS codes, and fix the list — codes are ordered per item, not per shipment.
- Send a complete specification for each position: name, brand, volume, composition, number of units in the consumer pack and in the transport pack. Any inaccuracy here migrates straight into the catalogue card.
- Agree where the codes will be applied — your plant, a consolidation warehouse abroad or a warehouse under customs control in Russia — and fix the cost and the responsibility for the operation in the contract.
- Rework the label artwork: a field for the marking code, consumer information in Russian, the EAC mark. Approve it before the print run, not after.
- Set up the routine for receiving code files from the buyer: format, transfer channel, who prints them, what happens with damaged or unused codes.
- Run a trial batch: apply the codes, photograph the packaging, and let the buyer check readability and the entry-into-circulation data before mass production starts.
- Collect the product documentation for conformity assessment — composition, purpose, test data — before shipment, not after the container arrives.
- Build two to three weeks into the production schedule for this cycle, and flag any change of pack, formulation or brand to the buyer as early as possible.
Frequently asked questions
Can we ship without codes and have the goods marked in Russia?
Yes, provided the codes are applied before the goods are entered into circulation — at a temporary storage warehouse or a customs warehouse. This is a legal route, but it is more expensive and slower than application on the supplier's side, and the lost days show up against your delivery date.
Who orders the codes — the factory or the buyer?
The participant of turnover orders them, that is the Russian importer. The factory can only apply the codes handed over to it, so registration in the system and the product descriptions stay in the buyer's area of responsibility. Accurate data and clean application stay in yours.
What happens to goods produced or bought before the requirement came in?
The full ban on the circulation of unmarked sanitary and hygiene products starts on 1 October 2027. Until that date existing stock can be sold through, but new orders are better planned with marking already factored in.
Does the marking code replace a certificate or a declaration of conformity?
No. These are two different systems: marking is responsible for traceability of a single unit, permit documents for proof of conformity. Both sets are required, and the code will not compensate for a missing certificate at the border.
Summary
From 1 September your Russian buyer has to be registered in the system and to order the codes, and from 1 October those codes have to be on the packaging. The most labour-intensive part of the job — the product descriptions and the label artwork — depends on data that only you can supply, and it is done well before the shipment. Applying the codes at the factory saves days at the warehouse in Russia and removes the risk of marking under customs control, but it requires quality control of the operation itself. Request a consultation and we will go through your specific shipment.
We can apply the marking codes at the consolidation warehouse in China and prepare the permit documents your consignee needs before the declaration is filed.
Read also:
- Baby Food and Children's Supplements Bound for Russia: Chestny Znak Codes, Documents and Labelling Before Shipment
- Russia Extends Frozen and Semi-Finished Food Marking Pilot: What It Means for Your Shipment
- Post-Release Declaration Amendments in Russia: What Your Buyer Will Ask You For and How to Answer Fast
- Toy Marking in Russia from 1 September 2026: What Your Shipment and Your Buyer Now Need
