Transshipment to Another Carrier After a Customs Warehouse in Russia: When One CMR Becomes Two Shipments and an ETrN Is Required

Two scenarios after customs clearance

The Ministry of Transport has outlined two scenarios that differ in practice by a single detail. The first: the vehicle clears customs at a temporary storage facility and continues on to the recipient’s final warehouse in Russia under the same CMR bill of lading. In this case, the international transport contract is not terminated; the entire shipment is considered a single international shipment, and an electronic waybill is not required for this leg of the journey. There is no need to submit the CMR to the state information system for electronic transport documents, as the law does not require it.

Second scenario: at the temporary storage warehouse or after it, the goods are transshipped onto another carrier’s vehicle for delivery within Russia. In this case, the shipment is divided into two separate stages—international and domestic. An electronic waybill is issued for the domestic stage.

Information on how the Russian party enters data in the declaration when using an electronic waybill is provided in the article on codes 02015 and 02016 and the shipment UID. For information on the e-CMR itself and the international segment of the supply chain, see the guide for importers and carriers.

Who Is Listed as the Shipper

For the domestic leg, the shipper listed on the waybill is the party to the contract of carriage for that leg. A temporary storage warehouse is not such a party and therefore is not recognized as the shipper. In practice, you should not expect the warehouse itself to issue the waybill on behalf of the shipper.

Clarify in advance with your Russian counterparty exactly who is entering into the contract of carriage for the domestic leg and will be listed as the shipper on the electronic waybill. If this is not specified, the vehicle will be held up after transshipment because the second carrier does not have a waybill.

Can the consignee issue the waybill themselves?

According to the clarification, a Russian consignee is entitled to issue an electronic waybill, designating themselves as both the shipper and the consignee, under two conditions. They must be a party to the contract of carriage for the leg from the customs warehouse to their own warehouse. They act as the shipper when acting on behalf of the cargo owner, and as the consignee when the cargo is delivered to their address.

However, an electronic waybill cannot be issued unilaterally, without the participation of the other parties to the contract of carriage: the rules governing the exchange of electronic transport documents do not permit this. The participation of the other parties to the contract of carriage is required. Therefore, a foreign supplier should expect that the Russian consignee will coordinate the issuance of the waybill with the carrier.

When Paper Documents Are Permitted

The Ministry of Transport also noted the exceptions. Paper waybills, orders, and requests are permitted if the shipper or consignee is a foreign legal entity that is not listed in the state register of accredited branches and representative offices of foreign legal entities. This follows from Ministry of Transport Order No. 262 dated June 1, 2026, which the publication cites. We do not analyze the order itself in this article, so please review its text before applying the exception.

What This Means for Your Shipment

1. Before shipping, confirm with the Russian buyer or consignee whether the cargo will be transferred to another carrier after passing through the customs warehouse. This changes the entire set of documents.
2. If a transfer is planned, make sure that the contract or shipment request specifies who is the party to the domestic transport contract and will act as the shipper.
3. Expect the Russian party to ask the domestic carrier to confirm in advance its readiness to work with an electronic waybill, as well as whether it has the necessary signature and access to the system.
4. Do not expect the customs warehouse to issue the waybill: it is not a party to the contract of carriage.
5. If the Russian consignee wishes to act as both the shipper and the consignee, the documentation must be coordinated with the carrier: the waybill cannot be issued unilaterally.
6. Keep both sets of documents: the CMR for the international leg and the waybill for the domestic leg.

We arrange delivery after customs clearance and help you organize the document flow as part of the customs clearance process.

Frequently Asked Questions

Is it necessary to submit the CMR to the GIS EPD system?
No, according to a clarification from the Ministry of Transport, the law does not require this.

When is an electronic waybill required after a temporary storage warehouse (TSW)?
When the goods are transferred to another carrier’s vehicle: domestic transportation is considered a separate shipment.

Can a temporary storage warehouse (SVH) act as the shipper?
No: a temporary storage warehouse is not a party to the contract of carriage and therefore is not recognized as the shipper.

Is this an official clarification, and where can it be found?
An industry publication reported on it, citing a letter from the ministry; we were unable to find the text of the letter in public sources, so in case of disputes, please check with the carrier and the Ministry of Transport.