Russia’s Dietary Supplement Labeling 2026. Per-Item Tracking, Withdrawal Rules, and Reporting Deadlines
A cashier scans the code at checkout. The customer leaves with the product. But in the Chestny ZNAK system, this package remains on the store’s balance. Six months later, Rospotrebnadzor arrives, finds discrepancies, and issues a fine of up to 300,000 rubles plus confiscation of goods. These cases are already happening, and with the transition to per-item tracking, there will be more.
Starting September 1, 2025, Russia’s dietary supplement market transitions to per-item tracking. Every shipment must now specify the code of each individual unit, and recipients must verify compliance upon receipt. Reporting errors that previously went unnoticed are now automatically flagged by the system. This article explains how to properly withdraw dietary supplements from circulation, which deadlines cannot be missed, and how to prepare for the new requirements.
Three Labeling Waves and Transition Periods
The government is implementing dietary supplement labeling in stages. Decree No. 886 dated May 31, 2023 (as amended November 28, 2025) establishes three waves of mandatory requirements with different dates and product codes.
| Wave | Labeling Start | Products Covered | PIA Transition |
|---|---|---|---|
| First | October 1, 2023 | Core codes (2106 90, 2936, etc.) | September 1, 2025 |
| Second | March 1, 2025 | Expanded list (1211 90, 3502 90, etc.) | March 1, 2026 |
| Third | March 1, 2026 | Fish liver oil (1504 10 990 0), enzymes (3507 90 900 0) | March 1, 2026 |
Transition periods apply to unlabeled inventory. Deadlines depend on product shelf life.
| Situation | Shelf Life up to 3 Years | Shelf Life over 3 Years |
|---|---|---|
| First wave stock (produced before October 1, 2023) | until August 31, 2026 | until August 31, 2027 |
| Second wave stock (produced before March 1, 2025) | until August 31, 2026 | until August 31, 2027 |
| Third wave stock (produced before March 1, 2026) | until August 31, 2027 | until August 31, 2027 |
After these dates, unlabeled dietary supplements must be written off. Sale is prohibited.
Two Tracking Modes and Their Differences
Until September 2025, most market participants operated under volume-grade accounting (VGA). The electronic universal transfer document (UTD) specified only the product code (GTIN) and quantity. The system automatically distributed codes from sender to recipient.
Starting September 1, 2025, per-item accounting (PIA) takes effect for first-wave dietary supplements. Each UTD must now list the specific DataMatrix code of every individual unit. The system verifies codes with the sender and records the transfer to the recipient.
| Parameter | VGA | PIA |
|---|---|---|
| UTD contents | GTIN + quantity | Each DataMatrix code |
| Scanning upon receipt | Optional | Mandatory |
| Mix-up detection | After the fact | At moment of receipt |
| Quantity error | May go unnoticed | Blocks the document |
Dietary supplements in small cylindrical packaging (length up to 7 cm, diameter up to 2 cm) remain under VGA permanently. Such surfaces cannot accommodate readable codes, and automatic scanners produce high error rates.
Nine Grounds for Withdrawal from Circulation
Withdrawal from circulation means the code is deactivated in the system and can no longer participate in transactions. Decree No. 886 (Section VIII, paragraphs 94-114) provides the following grounds.
Via online cash register:
Retail sale to end consumer
Sale between legal entities using cash register
Via personal account or system API:
Distance selling or sale by sample (e-commerce)
Sale through vending machines and parcel lockers
Export outside the EAEU
Export to EAEU countries (cross-border trade)
Sale not for resale (for buyer’s own use)
Sale under state secrets or restricted procurement
Destruction, expiration, loss
Each ground has specific required data fields and reporting deadlines.
Retail Sales via Cash Register
For retail sales using online cash registers, information transmits automatically through the fiscal data operator (FDO). The cashier scans the DataMatrix code, and the FDO transmits data to Chestny ZNAK in real time.
If the FDO contract does not include transmission to the labeling system or technical capability is lacking, the seller must submit information independently via personal account within 30 calendar days.
For participants in remote and hard-to-reach areas, all deadlines extend to 30 calendar days.
Since November 1, 2024, an online permissive mode has been active. At the moment of sale, the cash register queries Chestny ZNAK and receives confirmation whether the specific code may be sold. The system checks code registration, status, seller ownership, expiration date, and absence of blocks. If the code fails verification, the register displays a warning.
Starting March 1, 2025, offline verification mode is introduced. Valid code data is stored in the register’s memory and verified even without internet connection.
Distance Selling and Marketplaces
Online stores operate under different rules. Data transmits not at payment, but upon shipment from warehouse. Deadline: no later than 3 business days from shipment or no later than actual delivery date.
Required information includes participant TIN, withdrawal reason (distance selling, sale by sample, vending, parcel locker), identification code, primary document details, and product value.
When working with marketplaces, the withdrawal obligation depends on the partnership model. If the marketplace acts as commission agent and delivers from its warehouse (FBO), it submits withdrawal information. If the seller ships from their own warehouse for specific orders (FBS), the obligation lies with the seller.
Online stores selling dietary supplements without codes may be blocked without court order. Marketplaces do not accept unlabeled goods regardless of production date.
Write-Off and Destruction
When withdrawing due to expiration, loss, disposal, or destruction, participants must transmit information within 3 business days of actual withdrawal.
Required information: participant TIN, withdrawal reason, identification code, primary document name, date, and number. The primary document may be a write-off act, disposal act, or defect review committee report.
For exports, information must be submitted before actual removal, indicating the registration date and customs declaration number.
Sale for Own Use
When a company sells dietary supplements to another organization or individual entrepreneur not for resale (for example, for use in cosmetics production or employee distribution), this also constitutes withdrawal from circulation.
A buyer not registered in Chestny ZNAK signs an ownership transfer notification in UTD format. The seller transmits information to the system within 3 business days of shipment.
If the buyer later decides to resell, they must first re-enter the goods into circulation via special notification and perform labeling if necessary.
Product Returns
For returns from end consumers (individuals), the seller issues a receipt with «return of receipt» attribute. The FDO transmits data to Chestny ZNAK, and the code becomes active again. The product should not return to the sales floor until resale.
For returns from legal entities, the buyer generates a universal correction document (UCD) signed by both parties with electronic signatures. Returned codes are specified in the document. Upon UCD receipt, goods are again listed under the seller.
For returns of goods previously sold for own use, the buyer generates a return notification specifying codes and return document details. The seller generates a circulation entry notification if planning to sell them.
Relabeling When Code Is Damaged
If the DataMatrix label is torn, worn, or lost, the product cannot be sold in that condition. The seller must perform relabeling before returning the product to the sales floor.
Procedure:
Request a new labeling code from Chestny ZNAK
Apply the new DataMatrix to packaging or label
Submit relabeling information to the system: new identification code and damaged identification code
The old code is written off; the new one links to the same product card.
Obtaining a labeling code without a valid state registration certificate (SRC) is impossible. When registering products in the system, the SRC number must be specified. If the certificate is expired or missing, the system will refuse entry into circulation. According to Roskachestvo, over 60,000 cases of dietary supplement sales without state registration were detected on marketplaces in 2024.
Reporting Deadlines
| Operation | Submission Deadline to Chestny ZNAK |
|---|---|
| Entry into circulation (production, import) | Before offering for sale |
| Transfer between participants (circulation) | 3 business days from receipt |
| Retail sale via cash register | Real time (via FDO) |
| Retail sale without FDO | 30 calendar days |
| Distance selling | 3 business days or before delivery date |
| Write-off, destruction, loss | 3 business days |
| Export | Before actual removal |
| Sale for own use | 3 business days from shipment |
| Amendment of previously submitted data | 3 business days from change |
For participants in remote and hard-to-reach areas, all deadlines extend to 30 calendar days.
Penalties for Violations
Article 15.12 of the RF Administrative Code establishes administrative liability.
| Violation | Officials | Legal Entities |
|---|---|---|
| Production or entry into circulation without labeling | 5,000–10,000 ₽ + confiscation | 50,000–100,000 ₽ + confiscation |
| Sale, storage, transport without labeling | 5,000–10,000 ₽ + confiscation | 50,000–300,000 ₽ + confiscation |
| Transfer of goods without submitting data to system | 1,000–10,000 ₽ or warning | 50,000–100,000 ₽ |
For individuals (sole proprietors), the fine for selling without labeling ranges from 2,000 to 4,000 rubles plus confiscation.
Confiscation means seizure without compensation. If a batch cost one million rubles and the fine was 100,000 rubles, total losses exceed one million.
For large-scale violations, criminal liability applies under Article 171.1 of the RF Criminal Code. Large scale means unlabeled product value exceeding 400,000 rubles; especially large scale exceeds 1,500,000 rubles. Sanctions: fine up to 1,000,000 rubles and imprisonment up to 5 years.
The Federal Tax Service and Rospotrebnadzor have intensified inspections of labeled goods. The monitoring system automatically generates alerts for suspicious activity: «double sales» of the same code or sale of expired goods.
Action Plan
Verify SRC validity. Without a valid state registration certificate, the system will not issue labeling codes. If the SRC is expired or product composition has changed, submit renewal or reissuance documents in advance. Code generation costs 50 kopecks excluding VAT.
Conduct inventory of remaining stock. Compare Chestny ZNAK data with actual warehouse stock. Unlabeled dietary supplements with shelf life up to 3 years may only be sold until August 31, 2026. After this date, they must be written off.
Set up electronic document interchange (EDI). Ensure all suppliers and buyers are ready to exchange UTDs electronically with labeling codes specified. Paper invoices do not transmit information to the system. Under PIA, an error in even one code blocks receipt of the entire batch.
Implement aggregation. Grouping goods into case and pallet packaging speeds up shipment and receipt under per-item tracking. Instead of scanning each unit, scan the case or pallet code.
Train staff. Cashiers must know what to do if the scanner cannot read a code or the system issues a warning. Warehouse workers must understand write-off and relabeling procedures. Order pickers must verify codes when assembling e-commerce orders.
Compare system data with internal records weekly. Discrepancies discovered internally cost less to resolve than those found by Rospotrebnadzor.
Regulatory Framework:
1. RF Criminal Code, Article 171.1
2. Government Decree No. 886 dated May 31, 2023 «On Approval of the Rules for Labeling Dietary Supplements with Identification Means» (as amended November 28, 2025)
3. Government Decree No. 1680 dated November 30, 2024 (second-wave list expansion)
4. Government Decree No. 1953 dated November 28, 2025 (third wave and transition period extension)
5. RF Administrative Code, Article 15.12