Importing goods into the EAEU without EAC marking — why the December 2025 exemption ended and what to do now
For the better part of December 2025, importing goods from Kazakhstan and Kyrgyzstan without marking was permitted: first under Decree No. 778, and then Decree No. 912 extended this regime until December 25. On December 26, the exemption ended, and customs reverted to standard rules. Many companies are still adjusting.
The EAC (Eurasian Conformity) mark confirms that the manufacturer or importer has completed all conformity assessment procedures under the applicable technical regulations. Without it, goods cannot be released into circulation within the EAEU. Since December 2025, this rule applies without exception to all import routes.
How Marking Rules Have Changed for Imports
Prior to 2022, enforcement was less formalized. Decision No. 294 of the Collegium of the Eurasian Economic Commission (EEC) dated December 25, 2012, «On the Regulations on the Procedure for Importing Products into the Customs Territory of the Customs Union» (hereinafter — Decision of the Collegium No. 294) allowed marking to be applied after goods were released under a conditional release procedure.
On January 30, 2022, Decision No. 130 of the Council of the EEC dated November 12, 2021, «On the Procedure for Importing Products Subject to Mandatory Conformity Assessment into the Customs Territory of the Eurasian Economic Union (EAEU)» (hereinafter — Decision No. 130) entered into force. It repealed Decision of the Collegium No. 294 and established a new requirement: marking and conformity documents must be ready prior to filing the Goods Declaration (GD) under the procedure of release for domestic consumption.
Concurrently, the Federal Customs Service (FCS) and Rosaccreditation integrated their databases. Customs can now verify a certificate’s registry status in real time. A paper certificate with no corresponding entry in the registry does not exist for customs purposes.
In autumn 2025, the flow of goods across the Kazakh-Russian border surged. To relieve congestion at border checkpoints, Decree No. 778 of the President of the Russian Federation dated October 24, 2025, «On the Peculiarities of Customs Regulation on the Russian-Kazakh Section of the State Border» (hereinafter — Decree No. 778) introduced a temporary regime: goods from Kazakhstan and Kyrgyzstan could be transported by road without marking and without documents confirming their EAEU goods status, provided the consignee was a Russian legal entity. Decree No. 912 of the President of the Russian Federation dated December 9, 2025, extended this window until December 25. On December 26, the regime concluded.
In April 2026, Decree No. 261 of the President of the Russian Federation dated April 20, 2026, introduced another simplified procedure covering a broader range of import routes, but only until May 31, 2026. From June 1, the national System for Pre-shipment Cargo Registration (SPOT) is scheduled to launch, which will further tighten control over supplies from EAEU countries.
| Period | Regime | Regulatory Act |
|---|---|---|
| Until Jan 30, 2022 | Flexible control; marking permitted after release | Decision of the Collegium of the EEC No. 294 dated Dec 25, 2012 |
| From Jan 30, 2022 | Marking mandatory prior to filing the GD | Decision of the Council of the EEC No. 130 dated Nov 12, 2021 |
| Oct 25 – Dec 10, 2025 | Road transport import without marking from KZ/KG for legal entities | Decree of the President of the RF No. 778 dated Oct 24, 2025 |
| Dec 10 – Dec 25, 2025 | Extension of the temporary exemption | Decree of the President of the RF No. 912 dated Dec 9, 2025 |
| From Dec 26, 2025 | Standard procedure with no exceptions | Decision of the Council of the EEC No. 130 (as amended Dec 5, 2025, No. 118) |
| Apr 20 – May 31, 2026 | Temporary simplified regime | Decree of the President of the RF No. 261 dated Apr 20, 2026 |
Label Requirements by Technical Regulation
The unified EAC mark of conformity is applied to every unit of product, its packaging, or accompanying documentation. Its design and application procedure are established by Decision No. 711 of the Customs Union Commission dated July 15, 2011, «On the Unified Mark of Products Circulation on the Market of the Eurasian Economic Union Member States and the Procedure for Its Application» (hereinafter — Decision No. 711). The mark is applied to a product only after obtaining a certificate or declaration of conformity.
In addition to the EAC mark, each Technical Regulation (hereinafter — TR CU) establishes its own list of mandatory information required on the label. Requirements vary by product category.
Food Products (TR CU 022/2011). The label must include the product name, ingredient list in descending order of mass fraction, nutritional value, manufacturing date, expiration date, and storage conditions. All allergens must be listed separately, regardless of their quantity in the product. All information must be in Russian; Latin characters are acceptable only for the country of origin and the manufacturer’s address. An omitted allergen warning is one of the most frequent causes of import bans.
Light Industry (TR CU 017/2011). Fiber or material composition with percentage breakdown, size, and care symbols. For footwear, the materials of the upper, lining, and sole must be specified. Labels such as «eco-friendly» or «orthopedic» are prohibited without supporting documentation, and customs regularly verifies such claims.
Electronics and Low-Voltage Equipment (TR CU 004/2011, TR CU 020/2011). On the product itself: name, model, primary parameters (voltage, frequency, power output), trademark, and country of manufacture. If the product is too small, part of this information may be moved to the user manual, but the manufacturer’s name and model must remain on the housing. A printed user manual in Russian inside the packaging is part of the marking requirements — customs inspects it during physical examination.
Perfume and Cosmetics (TR CU 009/2011). The ingredient list may be provided in Latin characters using INCI nomenclature. The shelf life is indicated either by a specific date or a period from the date of manufacture. When the packaging is too small to accommodate all required information, a «hand on an open book» pictogram is applied to the bottle, and the remaining information goes on an insert leaflet.
| Parameter | Food (022) | Textiles (017) | Electronics (004/020) | Cosmetics (009) |
|---|---|---|---|---|
| EAC Mark | Mandatory | Mandatory | Mandatory | Mandatory |
| Language | Russian | Russian | Russian | Russian (INCI — Latin) |
| Composition | Full list, descending mass order | Fiber type and % | N/A (technical specs only) | INCI list |
| Manual / Insert | Not required | Rarely | Mandatory | Permitted for small sizes |
| Special Requirements | Allergens | Ban on pseudo-eco claims | Voltage, power | Precautionary measures |
Action Plan
Check whether your goods fall under the temporary regime of Decree No. 261. A simplified import procedure is in effect until May 31, 2026. Confirm whether it applies to your product category and route. After May 31, the full requirements of Decision No. 130 apply without exceptions.
Approve the label layout prior to shipment. Obtain photos of the marking for each article number from the supplier. Cross-check against three documents simultaneously: the certificate of conformity, the invoice, and the requirements of the applicable TR CU. A single-character discrepancy between the invoice and the label is sufficient grounds for a customs inspection.
Ensure that the conformity assessment applicant and the declarant match. Under paragraph 10 of Decision No. 130, only the conformity assessment applicant, or a person expressly authorized by them in writing, may use the certificate during customs declaration. If the declarant is a different party, a power of attorney or an authorization letter from the applicant is required.
Verify the certificate status in the Rosaccreditation registry. Open the registry at fsa.gov.ru and confirm: the status reads «Active,» all imported models are listed in the document, and the «Manufacturer» field matches the label data exactly.
If marking has not been applied, use the Customs Warehouse procedure (IM 70). Releasing unmarked goods for domestic consumption is impossible and constitutes a violation of Article 16.3 of the Code of Administrative Offenses (CAO) of the Russian Federation. The lawful path: place the cargo under the customs warehouse procedure, obtain permission to perform operations with the goods under Article 158 of the EAEU Customs Code, apply the marking, then file a new GD under IM 40. Additional costs are unavoidable, but this is the only legal alternative to returning the cargo.
Do not import test samples with the EAC mark already applied. Samples are imported using movement feature code 064, explicitly stating «Samples for Testing Purposes» in Box 31 of the Goods Declaration. Applying the EAC mark before receiving the official test report constitutes an offense. Samples must carry identification marking (article number, model) that links them to the test report and the future certificate.
For goods subject to the Chestny ZNAK (Honest Mark) system, verify the presence of a Data Matrix code. Footwear, clothing, perfume, tires, dairy products, and other categories require this code. Without it, the declaration will be rejected. Codes are applied either at the factory or in a customs warehouse, following the same framework as EAC marking.
Under Article 16.3 of the CAO RF, courts are increasingly applying confiscation — goods are seized even when the carrier declares the shipment as transit. Marking violations rarely end with just a fine. A pre-shipment inspection established as a standard business process costs significantly less than cargo detained at a temporary storage warehouse.
Regulatory Framework:
1. Article 16.3 of the Code of Administrative Offenses of the Russian Federation
2. Decision of the Customs Union Commission dated July 15, 2011, No. 711 «On the Unified Mark of Products Circulation on the Market of the Eurasian Economic Union Member States and the Procedure for Its Application» (as amended March 17, 2016)
3. Decision of the Collegium of the EEC dated December 25, 2012, No. 294 «On the Regulations on the Procedure for Importing Products into the Customs Territory of the Customs Union» (repealed January 30, 2022)
4. Decision of the Council of the EEC dated November 12, 2021, No. 130 «On the Procedure for Importing Products Subject to Mandatory Conformity Assessment into the Customs Territory of the Eurasian Economic Union» (as amended December 5, 2025, No. 118)
5. TR CU 022/2011 «Food Products in Terms of Their Labelling»
6. TR CU 017/2011 «On the Safety of Light Industry Products»
7. TR CU 004/2011 «On the Safety of Low-Voltage Equipment»
8. TR CU 020/2011 «Electromagnetic Compatibility of Technical Products»
9. TR CU 009/2011 «On the Safety of Perfume and Cosmetic Products»
10. Decree of the President of the Russian Federation dated October 24, 2025, No. 778 «On the Peculiarities of Customs Regulation on the Russian-Kazakh Section of the State Border of the Russian Federation»
11. Decree of the President of the Russian Federation dated December 9, 2025, No. 912 «On Amending Decree of the President of the Russian Federation dated October 24, 2025, No. 778»
12. Decree of the President of the Russian Federation dated April 20, 2026, No. 261 (simplified import procedure until May 31, 2026)
13. Article 158 of the Customs Code of the Eurasian Economic Union