Shipping PPE to Russia under TR CU 019/2011: Which Certificates Stay Valid and What Your Buyer Will Need

13 September 2026Trade Pulse

If you manufacture or supply protective clothing, safety gloves, helmets, respirators or fall-arrest systems and ship them to Russia and the CIS, your next few production runs depend on a date you probably do not track: the expiry date of your buyer's EAEU permit documents. The procedure for bringing the amendments to the Customs Union technical regulation "On the safety of personal protective equipment" (TR CU 019/2011) into effect has now been fixed. Certificates issued and declarations registered earlier are not cancelled — they work until their own expiry date — and goods that previously were not subject to mandatory conformity assessment at all get a separate transition window. For your shipment the consequence is blunt: Russian customs will release the goods declaration only while the document quoted in box 44 is still valid on the day of filing. From now on the sensible way to plan an order, a production slot and a sailing date is to count backwards from the certificate expiry date, not forward from the ETA of your container.

What changes in the permit documents for PPE

Decision of the EEC Board No. 115 of 08.09.2026 does not rewrite the safety requirements for protective equipment itself. It answers a different question, and one that matters far more for supply chains: what happens to paperwork issued under the previous wording of the regulation. The document comes down to four points.

Conformity assessment documents issued or registered before the date of entry into force of Decision of the EEC Council No. 40 of 13 March 2026 remain valid until their own expiry date.
While such a document is valid, the product may be manufactured and placed on the market in the EAEU — there is no need to re-issue anything retroactively.
For products that were not subject to mandatory conformity assessment before Decision No. 40 entered into force, a period of 18 months from the date that decision takes effect is established: throughout that period they may still be manufactured and placed on the market without TR CU 019/2011 conformity assessment documents.
Decision No. 115 itself enters into force 30 calendar days after its official publication.

What this means in practice for you as the shipper: there will be no stampede to re-certify entire catalogues, but there is no open-ended grace period either. Every article number you sell into Russia now carries its own personal date, after which a consignment can no longer be cleared against the old document — and the consignment that gets caught is usually the one already on the water.

Which articles fall under the regulation and which codes to look at

TR CU 019/2011 does not cover workwear in general, only articles intended to protect a person against specific harmful and hazardous factors. In practice that means protective workwear (HS groups 61 and 62), special footwear including articles with a protective toecap (group 64), knitted, leather and polymer-coated gloves (items in groups 61 and 42), safety helmets (group 65), goggles, visors and face shields (group 90), respiratory protection — respirators, half-masks, filters, gas masks (group 90), hearing protection, fall-arrest harnesses, lanyards and ropes, dielectric gloves and boots.

The decisive fork in classification is the intended purpose of the article. Ordinary corporate uniform with no protective properties falls under the light industry regulation, not under "the nineteenth". The mistake is expensive, because protective and non-protective articles can share the same HS code, and the inspector does not judge by the code — they look at the product marking, the operating documentation and the protective properties you yourself declare on the label and in the manual. If you are not sure an article is subject to mandatory conformity assessment at all, the correct move is to have your Russian buyer obtain a refusal letter or decision in advance, before you print labels and hangtags, rather than argue at the border crossing. Choosing the conformity assessment scheme and arranging the testing is what certification covers for a specific product range.

Shipping PPE to Russia under TR CU 019/2011: Which Certificates Stay Valid and What Your Buyer Will Need

Protective clothing, gloves and respirators bound for Russia: the expiry date on the certificate now sets the production and shipping schedule

Transition periods: before and after

Sort your own catalogue into three baskets — each one has a different scenario and a different deadline for you.

Situation	How it was	What applies under the new rules	What it means for your shipment
A TR CU 019/2011 certificate or declaration issued before Decision of the EEC Council No. 40 entered into force	The document worked under the general rules of the regulation	Stays valid until its own expiry date; manufacture and placing on the EAEU market are allowed on its basis	Ship freely, but check the expiry date against your production and sailing schedule, not against the order date
Products that were not subject to mandatory conformity assessment before Decision No. 40 entered into force	Imported and placed on the market without TR CU 019/2011 documents	For 18 months from the date Decision No. 40 takes effect they may still be manufactured and placed on the market without such documents	Use the window to run testing and build the technical file — not to postpone it
A new consignment after the current certificate or declaration expires	Renewal under the previous scheme	A document issued under the updated requirements of the regulation is needed	Samples, testing and the new document must be finished before the goods leave your factory

Eighteen months is not a blanket extension for all protective equipment. It applies only to products that previously were not subject to mandatory conformity assessment at all; goods that already have a certificate or declaration live strictly by the term of that document — and not a day longer.

Keep the production cycle in the picture as well. Between placing the order at the factory and filing the goods declaration in Russia, a sea shipment easily accumulates three to four months, so a certificate that is formally "still valid" when you confirm the order may already be expired by the time of customs clearance. The working rule is to start the application for a new document while at least six months remain on the old one. How that calendar is built for a specific product range is covered under customs clearance of clothing, footwear and accessories, and realistic transit times are set out under sea freight.

Identification marking of light industry goods

Conformity assessment under the technical regulation and mandatory marking with identification codes are two independent obligations, and closing the first one does not remove the second. Part of the light industry range, including certain items of work and protective clothing, falls within the scope of mandatory marking, so each article number has to be checked separately against the relevant list. If it is on the list, the identification codes must be applied before the goods declaration is filed, and the code data goes into the shipping documents.

It is cheaper and faster to apply the codes on your side. Marking at the factory costs noticeably less than repacking and labelling at a temporary storage warehouse in Russia, and it removes an extra link from the chain — one where the container sits idle while someone opens cartons. Your buyer orders the codes and passes them to you; your job is to apply them correctly and to keep the two data streams in sync: the information on the technical regulation label and the data behind the identification code must describe one and the same product. Any discrepancy surfaces during the inspection, and it surfaces at your buyer's cost first and your reputation second.

What this means for your shipment: a checklist for the shipper

Ask your Russian buyer for the register of all valid TR CU 019/2011 certificates and declarations covering your articles, with issue and expiry dates, and map it against your own order book and shipping plan for the next twelve months.
Tag the positions: a document issued before Decision of the EEC Council No. 40 entered into force works until its expiry date; a product that previously was not subject to mandatory conformity assessment falls into the 18-month window.
For articles whose document expires before the planned sailing date, start the new conformity assessment now — reserve production samples and budget the time to ship them. Sending test samples is a separate shipment with its own rules; see customs clearance of samples and catalogues.
Verify for each article number whether the item really is personal protective equipment; for borderline positions have the buyer obtain a refusal letter or decision before production starts.
Re-check the HS codes and the goods description in the contract and the invoice: the wording must match what is stated in the permit document, article number for article number.
Notify your buyer before, not after, any change of article number, colour, outer fabric or component — under the certificate that is a different product, and at the border it reads as a discrepancy.
Check the product marking and the operating documentation against the regulation, and separately against the mandatory identification marking lists.
Build slack into the schedule: the updated document has to be in hand before the consignment leaves the factory, not on the day the container arrives at the port.

Frequently asked questions

Does our buyer have to re-issue a certificate obtained before the amendments?
No. Conformity assessment documents issued or registered before the date of entry into force of Decision of the EEC Council No. 40 of 13 March 2026 remain valid until their expiry date, and manufacture and placing of the product on the EAEU market are allowed on their basis.

From what date are the 18 months counted?
From the date Decision of the EEC Council No. 40 enters into force. The period applies only to products that, before that date, were not subject to mandatory conformity assessment under TR CU 019/2011.

Can we ship a consignment if the certificate expires while the goods are in transit?
Go by the date the goods declaration is filed in Russia: the document must be valid at that moment, not on the date of the bill of lading. A sea shipment from Asia takes weeks, so such consignments are better moved onto the new document in advance — otherwise the cargo sits at a temporary storage warehouse, and storage is paid for by the importing side, which in most contracts comes back to the supplier as a claim.

Who is responsible for the documents at clearance?
Responsibility for the accuracy of the declared information lies with the declarant in Russia, even when the declaration is filed by a customs representative. But the information itself comes from your documents — the invoice, the packing list, the labels, the technical file. That is why companies working with this product range run a pre-arrival audit of the permit documents: that review costs less than a declaration amendment and container demurrage.

What will the buyer ask us for?
Production samples for testing, the technical documentation for the article, labels and operating instructions matching the regulation, and a goods description in the contract and invoice that is identical to the wording of the certificate. If the article is on the identification marking list, codes applied at your factory as well.

Summary

Certificates issued and declarations registered earlier for personal protective equipment keep their force until they expire, and products that previously did not require mandatory conformity assessment have an 18-month period from the date the amendments to the regulation enter into force. That is not a reason to wait: every article number has its own date, after which the old document no longer covers the shipment. Sort your range into the three scenarios, make sure the descriptions in the permit documents, the contract and the invoice are identical, and start the re-certification early enough for the paperwork to be ready before the container leaves your factory. We handle the Russian side end to end — see customs clearance and turnkey logistics, or send us the details of a specific consignment and we will check it.

Send us your article list and the certificates your buyer holds — we will check what is still valid, what expires before your next shipment and what has to be re-issued under the updated regulation.

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