Russian Decree No. 867 explained: what changed on 9 August for goods subject to mandatory conformity assessment — and what your buyer will now need from you

1. What exactly changed on 9 August

Decree of the Government of the Russian Federation No. 353 of 12 March 2022 «On the specifics of permit activities in the Russian Federation» (Annex No. 18) introduced simplifications in the field of technical regulation. It was these simplifications that allowed importers to bring products in under a lighter conformity confirmation procedure.

Decree No. 867 does not abolish those simplifications altogether, but removes one category of goods from their scope. Paragraph 2 of the decree entered into force on 9 August 2026. From that date, goods included in a special list are governed by the general rules of Decision of the Council of the Eurasian Economic Commission No. 130 of 12 November 2021 «On the Procedure for importing products subject to mandatory conformity assessment into the customs territory of the EAEU».

We covered Decree No. 867 itself, and the extension of the simplified procedure until 1 September 2027, in an earlier article — «Power of attorney, declarations and certificates: what changes on import». The current clarifications add the practical application to that picture.

Formally this all happens on the Russian side of the border. In reality the documents and the marking that customs will now look for originate at your factory, which is why the change lands on the exporter's desk first.

2. Does it affect your goods: List No. 4114

The key question is whether the product falls within the list. It is approved by Order of the Ministry of Industry and Trade of Russia No. 4114 of 10 September 2024 and contains the EAEU HS codes of products to which the provisions of paragraph 6 of Annex No. 18 to Decree No. 353 do not apply.

If the declared goods correspond to that list, the simplified procedure is closed for them and control is exercised under Decision No. 130. If the goods are not on the list, the simplifications continue to apply.

Note that the list is built on HS codes in combination with the product name. A match by code alone does not automatically mean the goods fall under the restrictions, and conversely, a product with a similar description may sit under a different code. This is exactly the fork where disputes with the customs authority usually start, which is why code selection and a check of the permit documents should be done before the cargo is dispatched, not once it has arrived.

For the shipper there is a direct consequence: the wording on your commercial invoice and packing list is what the buyer's broker classifies from. A generic description such as «spare parts» or «equipment» leaves the classification open, and an open classification is what turns into a hold at the border.

Original permit documents are now required at the Russian border

3. Three requirements that are back in full

For products on the list the clarifications set out three specific requirements. Each of them ends up as a request addressed to you.

• Originals of the conformity assessment documents. When importing products subject to conformity assessment against mandatory requirements, the declarant confirms compliance with technical regulation measures by providing details of the conformity assessment documents — with originals of those documents to be presented to the customs authorities (paragraph 8 of Decision No. 130). In practice this means the paper original has to be physically in Russia by the time the declaration is filed, so courier time now sits on the critical path of your shipment.
• Proof of the right to use the documents. Where certificates of conformity or declarations of conformity have been issued or registered for serially produced products, the declarant must prove the right to use those documents. The right is proven by copies certified with the seal of the applicant in the conformity assessment procedure or of the manufacturer (paragraph 10 of Decision No. 130). In most supply chains the manufacturer is you — so expect a request for stamped certified copies, and often a covering letter authorising your buyer to use the document.
• Mandatory marking. Products may not be imported into the Russian Federation without the marking required by the mandatory requirements, including without the EAC single mark of product circulation on the EAEU market. The mark goes on the product, the packaging or the label, depending on the applicable technical regulation — and it is applied on your production line, not at the border.

The practical meaning is simple: for goods on the list, the old approach of finding a suitable declaration in the register and quoting its number in the customs declaration no longer works. Your buyer can no longer lean on a third party's paperwork without documents that carry your seal.

The rules apply at the moment of declaration, not at the moment of shipment: a consignment that left your factory before 9 August but is declared after that date is cleared under the new requirements.

Goods on the list are controlled under the general rules: original documents and EAC marking

4. Table: before and after

A comparison of the approaches to conformity confirmation for products covered by Order No. 4114.

5. What the exporter should do now

1. Ask your buyer which HS code they will declare and check that code against List No. 4114 in combination with the product name. One code covering several of your articles is a reason to check each of them separately.
2. Establish who holds the certificate or declaration. If it is you as the manufacturer, or the applicant you appointed, prepare certified copies with your seal in advance instead of waiting for the request to arrive with the vessel.
3. Plan the logistics of the originals. Send the paper documents by courier together with, or ahead of, the shipping set. Documents that travel after the cargo are the single most common reason the goods sit at a temporary storage warehouse.
4. Move EAC marking onto the production line. Applying the mark at the factory is cheaper and faster than solving the problem at a warehouse in Russia, where re-marking requires customs permission and extra handling.
5. Recalculate your lead times. Collecting and certifying documents adds days to the period before the declaration can be filed. Build that buffer into your delivery commitments, especially for perishable and seasonal goods.
6. Review consignments already in transit. Anything declared after 9 August falls under the new requirements, so agree with your buyer in advance who bears demurrage and storage costs if the paperwork is late.

If you are unsure about the status of a specific consignment, the specialists at iCustoms can check the documents on the Russian side and handle customs clearance so that the cargo is not stopped at the border. We can also take over the transport leg itself — by sea, rail or air — or handle the shipment end to end.

6. Frequently asked questions

Has the simplified procedure been cancelled completely?
No. For products not included in the list under Order No. 4114 of the Ministry of Industry and Trade, the simplifications continue to apply. The change affects only goods on the list.

Can our buyer still use another company's certificate?
Yes, but the right to use it now has to be proven: a copy of the document certified with the seal of the applicant in the conformity assessment procedure or of the manufacturer must be provided.

Is an electronic copy enough?
For goods on the list the clarifications state directly that originals of the conformity assessment documents must be presented to the customs authorities. Send scans to keep the process moving, but the paper still has to travel.

What happens if the goods arrive without the EAC mark?
Import of products without the marking required by the mandatory requirements is not allowed. The issue has to be resolved before release, which means idle time and additional storage costs — usually allocated by the delivery terms in your contract.

Does this apply to a shipment that is already on the water?
Yes. The requirements apply at the declaration stage, so a consignment dispatched before 9 August will be cleared under the new rules if it is declared after that date.

Summary

The simplified procedure has not disappeared — it continues to apply to all goods except the positions in List No. 4114 of the Ministry of Industry and Trade. But for anything on that list the freedom is gone: originals of the conformity assessment documents, certified copies where a third party's certificate is used, and mandatory EAC marking applied before shipment. Check the HS codes and the paperwork for the consignments you have in transit right now — they will be cleared under the new rules. Request a consultation and we will go through your specific shipment.

Send us your HS codes and product description and we will check them against List No. 4114 before your goods leave the factory.

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