War Risk Insurance in Russian Customs Value: What Your Buyer Will Ask You For

When your policy enters the Russian customs value

When customs value is determined by the transaction value method, additions listed in paragraph 1 of Article 40 of the EAEU Customs Code are made to the price actually paid or payable. Those additions include the costs of carriage of the goods to the place of arrival in the customs territory of the Union, the costs of loading, unloading and handling, and the costs of insurance in connection with those operations.

The Code contains no separate exclusion for war risk cover specifically. The logic is simple: what matters is not the reason the policy became expensive, but the link between the insurance cost and the carriage and handling performed before the goods arrive in the EAEU. If a consignment of machinery moving by sea is insured against a package of risks including war risks up to the Russian port, and the premium is documented, that amount is taken into account when the customs value is built.

In practice this applies to every kind of cargo where insurance is normal commercial practice: production lines and machine tools of HS chapter 84, electrical equipment of chapter 85, project shipments with a high unit value. The more valuable the consignment, the more visible the premium is inside the calculation base — and the closer the inspector will look at the figures your buyer has entered in the declaration, all of which come from documents issued by you.

Cost, insurance and freight: where the line runs

The classic cost-insurance-freight bundle is split on a geographic principle. Everything relating to operations performed before the goods arrive at the place of arrival in the customs territory of the Union goes into the additions. Costs relating to operations after the place of arrival are not added under subparagraph 6 of paragraph 1 of Article 40 — the Code separately allows the costs of carriage from the place of arrival across the territory of the Union to be excluded from the customs value where the established conditions are met.

This is where the practical difficulty starts, and it is a difficulty created on your side of the deal. An insurer rarely thinks in categories of EAEU customs law: it issues a single warehouse-to-warehouse policy in which the ocean leg and the inland delivery to the consignee's plant are merged into one premium. If you sell DAP or DDP to a city inside Russia, that single premium is the default. Convenient for you, a source of dispute at the border. The same geography question shapes the whole quotation on sea freight shipments, where cover is almost always arranged for the entire chain at once.

If a single policy covers both the international leg and risks arising after the goods arrive in the EAEU, the premium must be split in the documents — by an addendum to the contract, by separate lines in the premium invoice, or by a statement from the insurer. Without that split, Russian customs will proceed on the basis that the entire premium relates to the international leg, and your buyer will pay duty and VAT on all of it.

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

One policy, several goods: two ways to allocate the premium

One insurance contract often covers several product lines, or even several shipments. Such costs cannot be attributed to a single line of the declaration at will. The procedure for calculating the additions is set out in Decision of the Board of the Eurasian Economic Commission No. 83 of 22 May 2018: as a general rule, insurance costs relating to several goods are allocated in proportion to the value of each good in the total value of the goods to which those costs relate.

A simple calculation. Goods A are imported at a value of USD 70,000 and goods B at USD 30,000; the total value of the consignment is USD 100,000 and the insurance premium for the carriage is USD 2,000. Goods A account for 70% of the cost, that is USD 1,400; goods B for 30%, that is USD 600. Those are the amounts added to the price of the respective goods. Note what this requires from your paperwork: a commercial invoice that states a value per line item, otherwise the proportion cannot be reproduced from documents at all.

Since 3 January 2025 an amendment introduced by Decision of the Board of the EEC No. 137 of 2 December 2024 into paragraph 1 of Decision No. 83 has been in force. The special mechanism was extended to insurance costs: at the declarant's option, the total amount of insurance costs relating to several goods may be added to the price of the good on which import duty is paid at the highest ad valorem rate, or the highest ad valorem component of a combined rate. If a consignment contains items at 5%, 10% and 15%, the whole premium may, subject to the conditions of Decision No. 83, fall on the item with the highest rate.

The special mechanism is an alternative, not an automatic saving. The economic effect depends on the structure of the consignment and on the way the customs payments are calculated, so both scenarios should be run before the declaration is filed, not after release. For you that translates into a deadline: the insurance pack has to reach the buyer before the goods do.

What customs will ask your buyer to produce

Additions under Article 40 of the EAEU Customs Code must be based on reliable, quantifiable and documented information. If that information is absent, the transaction value method is not applied — and the consignment moves to the fallback methods, with all the consequences for the amount payable.

The set of papers that establishes both the amount paid and its link to a specific carriage usually includes:

• the insurance policy or insurance contract stating the period and the scope of cover;
• the invoice for the insurance premium;
• evidence that the premium was paid;
• the transport documents for the corresponding carriage;
• information making it possible to establish which goods the insurance covers;
• the calculation allocating the premium between the product lines.

Check the wording of the policy separately: the period of insurance, the point at which cover ends, and the list of insured risks. Those are exactly the lines the inspector compares with the bill of lading and the delivery terms. If you are the party that buys the cover, you are the only party that can produce them — which is why they belong in the shipping document pack you send, not in an email exchange started once the cargo is already in port. For complex machinery it is easiest to assemble this set together with the rest of the file at the preparation stage for customs clearance of equipment and machine tools.

What this means for your shipment

1. Check who buys the cover under your contract. On CIF, CIP, DAP and DDP terms it is you — which means the documents Russian customs will want are in your files, not your buyer's.
2. Open the current policy and establish where cover ends: at the place of arrival in the EAEU, or at the door of the consignee's warehouse inside Russia.
3. If the cover is through cover, ask the insurer for a written split of the premium by leg of the route. An addendum obtained now is cheaper than any subsequent customs value adjustment.
4. Issue the premium invoice so that the amount is tied to this specific carriage — with a reference to the bill of lading, the booking or the consignment.
5. If the policy is written on annual turnover, obtain a document from the insurer carving out the share attributable to this shipment, together with the basis for the carve-out.
6. Give your buyer a commercial invoice and packing list with a value per line item, so the premium can be allocated between goods and the figures reproduced from the paperwork.
7. Send the insurance pack — policy, premium invoice, proof of payment, split by leg — together with the shipping documents and ahead of arrival. The declarant needs a day or two to compare the two allocation options before filing.
8. Keep the complete file. Post-release checks in Russia arrive months later, and the requests for clarification come back to the supplier who issued the documents.

Frequently asked questions

Is the sum insured the same thing as the premium?
No. The sum insured is the limit of the insurer's liability, that is the maximum possible payout. What enters the customs value is not that figure but the actual insurance cost — the premium paid or payable.

We sell FOB or EXW, so insurance is the buyer's problem. Does any of this concern us?
The cover and its documents are then the buyer's, but the allocation of the premium between goods still relies on your commercial invoice. Without a value per line item the buyer cannot reproduce either allocation method from the documents, and the questions come back to you.

Can the customs value be corrected after the goods are released?
Yes, a mechanism for amending the information in a declaration after release exists and is used when the final amount of insurance or transport costs becomes known later. But it always costs more time and attracts more attention from customs than a correct calculation at the filing stage, so treat it as a fallback.

Does including the premium affect anything other than the import duty?
The fee for the performance of customs operations is tied to the customs value, so a change in the base affects every payment calculated from it — the duty, the VAT and the fee.

Our policy is written on annual turnover rather than on a specific shipment. What do we do?
The part of the premium relating to this particular carriage has to be carved out, and the method of carving it out has to be supported by documents from the insurer. An arbitrary calculation with no supporting paperwork will not be accepted.

Summary

Insurance of the international carriage up to the place of arrival in the EAEU is included in the customs value regardless of which risks the policy covers, war risks included. Where several goods are involved, the default is allocation of the premium in proportion to their value, but since 3 January 2025 the declarant may, in the cases provided for, put the whole amount on the good with the highest ad valorem rate. For the exporter the practical task is narrow and entirely within your control: a policy whose cover is clearly delimited at the EAEU border, a premium invoice tied to the specific carriage, proof of payment, and an invoice with values per line item — all of it sent ahead of the cargo. Request a consultation and we will go through your shipment and the end-to-end delivery and customs clearance file for it.

Send us your shipping and insurance documents and we will check how the premium will land in the customs value of your consignment before the goods reach the Russian border.

Request a consultation