Russia Can Now Block EAEU Certificates from Kazakhstan. What Decree No. 1669 Means for Importers
For many years, importers used a simple scheme: certify goods in Kazakhstan, obtain a document under EAEU technical regulations, and safely import products into Russia. A single economic space, mutual recognition, a unified registry — all of this worked as an argument before the customs inspector. Since November 30, 2025, this logic has ceased to apply.
Decree of the Government of the Russian Federation No. 1669 dated October 27, 2025 changed the rules for all certificates of conformity (CoCs) and declarations of conformity (DoCs) issued in other EAEU member states. State control bodies are now entitled to suspend the validity of such documents on the territory of Russia without coordination with the Eurasian Economic Commission (EEC) and without lengthy interstate negotiations. This article examines what exactly has changed, who bears the risks, and what companies working through Kazakh certification should do.
Why Kazakhstan Became a Popular Route
The Treaty on the Eurasian Economic Union (EAEU), signed in 2014, established the principle of mutual recognition: a CoC or DoC issued in any member state grants the right to free circulation of goods throughout the entire Union. The unified EEC registry recorded valid documents, and formally this was sufficient for customs clearance.
In practice, a noticeable disparity in administration emerged. Russia was building strict digital traceability through the Federal State Information System (FGIS) of Rosaccreditation: requirements for test reports, sample selection acts, and physical import of batches for testing became tougher year after year. In Kazakhstan and Kyrgyzstan, the regime remained more lenient — certification bodies were more willing to accommodate applicants, and the requirements for the evidence base were interpreted differently.
Thus, a market of «certification arbitrage» emerged. Electronics, children’s goods, and light industry products were certified in Almaty or Bishkek, received documents bearing the EAC mark, and were imported into Russia. The cost of such certificates was significantly lower than Russian ones, and real testing was often not conducted at all.
The Federal Service for Accreditation (Rosaccreditation) and the Federal Customs Service (FCS) classified such documents as «paper» documents — issued without any actual verification of the products. Manufacturers who conducted a full testing cycle incurred real laboratory expenses and lost their pricing advantage to those who paid several times less for paper documents.
What Changed as of November 30, 2025
Decree of the Government of the Russian Federation No. 1669 dated October 27, 2025 amended Decree No. 936 dated June 19, 2021 «On the Procedure for Registration, Suspension, Resumption, and Termination of Declarations of Conformity, Declaring Them Invalid, and the Procedure for Suspension, Resumption, and Termination of Certificates of Conformity, Declaring Them Invalid» (hereinafter — Decree No. 936).
Decree No. 1669 creates two independent suspension mechanisms depending on who identified the issue.
The first operates through state control (supervision) bodies. If, during inspections, customs control, or market monitoring, a non-compliance with the requirements of EAEU Technical Regulations (TR EAEU) is detected — or if the manufacturer, seller, person performing the functions of a foreign manufacturer, or certification body fails to provide evidentiary materials upon request — the state control body makes a suspension decision. Within one working day, the information is entered into FGIS Rosaccreditation and published on the Rosaccreditation website.
The second mechanism involves Rosaccreditation as the national accreditation body. If the FCS transmits information on the import of products accompanied by a CoC or DoC for which the system contains no records of test reports, Rosaccreditation makes the suspension decision. The timeframe for entering this into the registry is the same: one working day.
| Parameter | Before (until Nov 30, 2025) | Since Nov 30, 2025 |
|---|---|---|
| Who initiates suspension | Only through the EEC mechanism | State control bodies (independently) or Rosaccreditation (triggered by the FCS) |
| Grounds for suspending DoC | List of violations within the RF only | Added: non-compliance with TR EAEU and failure to provide evidence upon request |
| Grounds for suspending CoC | Same as above | Same additions plus: absence of test report records per FCS data |
| Speed of registry update | 3 working days (para. 35 of Decree No. 936) | 1 working day from the date of the decision |
| Notification of the issuing country | Not separately provided | 5 working days to notify the EEC and the authorized EAEU body of the issuing state |
| Status in other EAEU countries | Single status across the entire Union | Suspension applies only on the territory of the Russian Federation |
The last row is a key detail of the new mechanism. The document is legally «split»: it continues to be valid in Kazakhstan or Belarus, but is blocked in Russia. Appealing to the unified EEC registry will not help here, since the Unified Automated Information System (UAIS) of the customs authorities is synchronized with FGIS Rosaccreditation — a blocked document will not allow customs clearance.
Decree No. 1669 was adopted in execution of instructions of the President of the Russian Federation given at a meeting with entrepreneurs on May 26, 2025. At the time, the business community raised the issue of unfair competition from importers using «paper» certificates.
The Main Vulnerability — The Sample Trail
The absence of documentary evidence confirming the import of samples for testing is the most frequent reason for suspending certificates from Kazakhstan. Decree No. 1669 directly names failure to provide test reports as one of the grounds.
The Russian certification model requires a complete chain of evidence. Samples must cross the border and be recorded in the cargo customs declaration (CCD) under procedure code 064. They are then delivered to an accredited laboratory, which issues an acceptance act. The laboratory conducts the tests and issues a test report. Based on this report, the certification body issues the document.
Breaking this chain at the first link deprives all subsequent documents of evidentiary value. Under the «Kazakh scheme,» samples were physically not imported, and test reports appeared without any material basis. Without a CCD for the samples, the entire subsequent package of documents proves nothing legally.
Decree No. 936 sets out the archive requirements explicitly. For each document, the following must be retained: the contract with the applicant, the customs declaration for the samples, transport documents, and — for serial production — evidence of the certification body’s staff having visited the production site. During a Rosaccreditation inspection, the absence of these documents leads to cancellation of the conformity document and revocation of the body’s right to operate.
Risks for Business
Using a CoC or DoC that is subsequently found to have been issued with violations entails administrative liability under Article 16.2 of the Code of Administrative Offences of the Russian Federation (KoAP RF) «Non-declaration or false declaration of goods,» as amended by Federal Law No. 560-FZ dated December 29, 2025.
For situations involving EAEU «paper» certificates, the most likely ground is Part 3 of Article 16.2: submitting false information about goods or presenting invalid documents that served as the basis for non-compliance with prohibitions and restrictions under TR EAEU. The penalty for legal entities ranges from RUB 50,000 to RUB 300,000, with or without confiscation of goods. If the certificate was used to understate customs duties, Part 2 of the same article applies: a fine ranging from one-half to twice the amount of unpaid duties. In both cases, the operative wording is «served or could have served as the basis,» meaning intent does not need to be proven.
Marketplaces add another layer of pressure. Large online trading platforms are connected to FGIS Rosaccreditation. As soon as a certificate’s status changes to «suspended,» the product is automatically hidden from the storefront.
Appealing to the mutual recognition provisions of the EAEU Treaty (Articles 51–53) in a dispute with a customs inspector or a Rospotrebnadzor official is practically useless. The control mechanism under Decree No. 1669 operates at the level of Russian national law and requires no coordination with supranational bodies.
What to Do
If a company uses CoCs or DoCs issued in Kazakhstan or Kyrgyzstan for supplies to the Russian market, here is the recommended sequence of actions.
Conduct a document audit. Compile a register of all CoCs and DoCs with KZ and KG country codes used for customs clearance in Russia. In parallel, check the status of each document in FGIS Rosaccreditation at fsa.gov.ru: the status in Kazakhstan’s national registry and in the Russian system may not match.
Verify the sample trail. For each certificate, locate the CCD for the import of samples into Kazakhstan under procedure code 064. The CCD release date must precede the date of the test report. If there is no CCD, the certificate is in a high-risk zone.
Categorize documents by risk zone. Red zone: certificates without a CCD for samples — immediate suspension of use and initiation of recertification in Russia. Yellow zone: CCD exists, but test reports are incomplete or do not cover the full product range. Green zone: complete package consisting of the CCD, test reports, sampling acts, and laboratory records.
Establish a procedure for responding to requests. State control bodies may request evidentiary materials at any time. Define who in the company receives such requests, within what timeframe and in what format they respond, and where electronic copies of all documents are stored. The absence of a procedure becomes apparent precisely when the inspector is already waiting for a response.
Plan a transition to Russian certification. For high-volume items, the direct route is certification through Russian bodies with a full testing cycle. It costs more, but it is the only way to obtain a document that is resilient to audits. For niche products, EAEU certification remains viable — provided there is a transparent logistics chain for samples and a reliable certification body is selected.
Decree No. 1669 sets a long-term course. The mechanism is already in operation, and Rosaccreditation and the FCS will apply it more actively as their cooperation matures. Those who adapt in advance will gain time.
Regulatory Framework:
1. Article 16.2 of the Code of Administrative Offences of the Russian Federation «Non-declaration or false declaration of goods» (as amended by Federal Law No. 560-FZ dated December 29, 2025)
2. Decree of the Government of the Russian Federation of June 19, 2021, No. 936 «On the Procedure for Registration, Suspension, Resumption, and Termination of Declarations of Conformity, Declaring Them Invalid, and the Procedure for Suspension, Resumption, and Termination of Certificates of Conformity, Declaring Them Invalid»
3. Decree of the Government of the Russian Federation of October 27, 2025, No. 1669 «On Amending Decree of the Government of the Russian Federation No. 936 dated June 19, 2021»
4. Treaty on the Eurasian Economic Union of May 29, 2014 (Articles 51–53, Section X «Technical Regulation»)