Shipping to Russia in 2022: New HS Codes and the Conformity Papers Your Buyer Will Ask You For

What changed at the start of 2022

Three changes affect almost every consignment arriving in Russia, and two of them depend directly on documents that only you, the supplier, can issue.

1. Updated EAEU HS nomenclature. The new list took effect on 1 January 2022. For some product groups the codes and the duty rates were adjusted, so the classification your buyer used last year may no longer be the one that applies to the same article.
2. Narrower conformity exemptions. On 30 January 2022 Decision No. 130 of the EEC Council replaced Decision No. 294. The document that lost force allowed goods subject to the technical regulations of the Customs Union to be imported without a certificate or declaration of conformity if a company brought them in as single items for its own production needs. That general relief is gone and has been replaced by four narrow cases.
3. New payment details for advance customs payments. From 1 January 2022 they go to a different budget classification code, 153 1 10 09000 01 1000 110. Nothing here is yours to do, but money sent to the old details is not credited on time, and a consignment cannot be released until the payment lands. In the first weeks of the year it is worth confirming with your customer that funds are already on their customs account before the truck or vessel arrives.

New HS nomenclature: check the code before you ship

The HS code is chosen by the declarant in Russia, but it is chosen from your documents: the product description, composition, material, capacity and purpose stated in the invoice and the technical specification. If the description is short and generic, the classification is a guess, and under a revised nomenclature a guess is more likely to be wrong than it was a year ago.

A wrong code has two consequences for you. The duty and VAT your buyer calculated no longer match the amount customs demands, and the deal economics that were agreed with you fall apart. And the code determines whether the goods fall under a technical regulation at all — that is, whether a certificate is needed. Ask your customer for the code they intend to declare and check that it corresponds to what you actually produce; the same check is normally part of customs clearance work, and it is cheaper to do it before shipment than after arrival.

If several articles travel in one consignment, list them separately in the invoice with quantities and values per line. A single lump-sum line for a mixed pallet forces the declarant either to classify everything at the highest rate or to request corrected documents from you, which costs days of storage.

Three regulatory changes that move part of the paperwork onto the supplier's side

Conformity assessment after Decision No. 130

The new order leaves four situations in which goods subject to the technical regulations may be brought in without confirmation of conformity, and each of them puts a condition on the paperwork you supply.

• Samples for representative purposes — as souvenirs or advertising materials, in the quantity provided for by the transaction. The purpose and the quantity must therefore be visible in the contract and the invoice, not merely understood between you and the buyer.
• Raw materials and components for production — only where the manufacturer of the finished product is the declarant. If your goods are ordered by a trading house or a distributor that does not itself manufacture, this route is closed.
• A single item for the declarant's own needs — one specimen, with no right of alienation or transfer to third parties. A test machine sent to a dealer for resale does not qualify.
• Someone else's conformity documents for serially produced goods — usable in declaring only if the applicant or manufacturer named in the document has provided the declarant with a copy certified by that applicant or manufacturer.

The last point is where most delays start. If your Russian customer is not the holder of the certificate or declaration, a scan from your website or a PDF forwarded by e-mail is no longer enough — they need a copy certified by the applicant or manufacturer named in the document, and the goods wait at the border until that copy is in their hands.

Two practical consequences follow. First, decide in advance who will hold the conformity document for the Russian market: you as the foreign manufacturer, your importer, or a distributor — and if it is you, plan how certified copies will be issued and couriered for every buyer. Second, if the product has no valid document at all, the certificate or declaration has to be obtained before the goods move, not after they arrive; that is a separate procedure with its own timeline, and certification for the EAEU market normally has to start weeks ahead of the shipping date.

Samples are exempt only in the quantity provided for by the transaction, so write the purpose and the number of pieces into the contract and the invoice — an unexplained carton of "free samples" is now treated as a commercial consignment requiring full conformity documents.

For catalogues, showroom pieces and pre-contract samples it is worth agreeing the wording with the customs representative who will handle clearance of samples and catalogues before you print the invoice.

Before and after: what your buyer can no longer do

What to do before your next shipment

1. Ask your customer which HS code they will declare under the new list, and confirm that your product description, material and technical data support it.
2. Establish whether the goods fall under a technical regulation of the Customs Union. If they do, agree in writing who holds the certificate or declaration for the Russian market.
3. If the buyer will declare on your document, issue a copy certified by you as the applicant or manufacturer and send the hard copy in advance — not together with the cargo.
4. For samples, state the purpose and the exact quantity in the contract and the invoice, and keep the quantity consistent with what the contract provides.
5. For components and raw materials, confirm that your consignee is the actual manufacturer of the finished product. If it is a trading company, plan on full conformity documents.
6. For a single machine or device, obtain the buyer's written confirmation that it is for their own use with no resale or transfer.
7. Itemise mixed consignments line by line in the invoice, with quantity and value per article.
8. For shipments arriving in the first weeks of January, confirm that the customs advance payment has been credited under the new details before the goods reach the border.

Frequently asked questions

Can I still send product samples to a Russian client without conformity documents?
Yes, but only as representative samples, souvenirs or advertising materials, and only in the quantity provided for by the transaction. The purpose and the quantity have to be visible in the contract and the invoice.

Our buyer is a distributor, not a manufacturer. Can they import our components without a certificate?
No. The exemption for raw materials and components applies only where the declarant is the manufacturer of the finished product. A distributor needs the full conformity documents.

We already hold a certificate of conformity. Is a scan enough for our customer?
No. If your customer is not the applicant named in the document, they may declare the goods on it only with a copy certified by the applicant or manufacturer. Plan how and when that certified copy reaches them.

Will the duty on our product change under the new nomenclature?
Duties were corrected for some product groups, not for all. The code your product falls under has to be checked against the new list before the price and delivery terms are confirmed.

Summary

From 1 January 2022 the EAEU applies an updated HS nomenclature with corrected duties for some groups, and from 30 January Decision No. 130 leaves only four narrow cases in which goods subject to the technical regulations may be cleared without confirmation of conformity. For a supplier this means three concrete things: a precise product description in the invoice, an agreed HS code, and certified copies of conformity documents in the buyer's hands before the cargo moves. Everything that is missing at that moment turns into waiting time at the border. Request a consultation, and we will go through the documents for your specific shipment.

We will check the HS codes and conformity documents for your shipment against the new EAEU list before the goods leave your factory.

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