ST-1, EAV, and Form A — zero duty on EAEU imports. Which certificate your supplier must provide
Many importers discover this instrument too late — only after the first customs duty has already been paid. The rule is simple: if goods originate from a country with which the EAEU has a preferential agreement, the import duty can be reduced to zero or significantly lowered. The only condition is a properly executed certificate of origin.
A certificate of origin is neither a bureaucratic relic nor «just in case» insurance. It is a financial document. For a pharmaceutical importer bringing in equipment or substances from Uzbekistan, Vietnam, or Serbia, the difference between having and not having a certificate amounts to percentage points of the duty rate multiplied by shipment volume. With an annual turnover of several million dollars, such savings become a compelling argument when selecting a supplier.
There are several certificate forms, each with its own rules, issuing authorities, and verification risks. Let’s break them down in order.
Why Some Goods Require Duties and Others Do Not
The EAEU customs tariff is structured as follows: every product has a base rate under the Common Customs Tariff (CCT) of the EAEU. This rate applies by default. If goods originate from a country with which the Union has concluded a preferential agreement, a reduced or zero rate applies instead.
To apply the preferential rate, the declarant must document that the goods originated from the partner country. This proof takes the form of a certificate of origin or a declaration of origin.
Two types of preferential regimes operate within the EAEU. The first covers free trade agreements (FTAs) with specific countries (Vietnam, Iran, Serbia, and CIS states). The second is the EAEU’s Unified System of Tariff Preferences (USTP), which the Union extends unilaterally to developing and least developed countries. Each regime produces its own certificate form.
Preferential certificates (ST-1, EAV, Form A) reduce or eliminate the duty. Non-preferential certificates only confirm origin for non-tariff regulation purposes — anti-dumping measures, statistics, government procurement — but do not grant any tariff benefit.
How the Preference Map Changed After 2021
Until October 2021, importers from many countries benefited from reduced rates under the GSP system (Generalized System of Preferences; called the USTP within the EAEU). The list covered 103 developing countries: China, Vietnam, Korea, India, Turkey, Brazil, Argentina, and dozens of others.
EEC Council Decision No. 17 dated March 5, 2021 removed 75 states from that list. From October 12, 2021, USTP preferences for goods from China, Vietnam, Korea, Turkey, and India ceased to apply. A Form A issued for those countries after that date lost its standing as a basis for duty reduction.
Duties on goods from Vietnam or Serbia did not revert to base levels, however: both countries are covered by separate FTA agreements. They require special certificate forms — EAV for Vietnam, ST-2 for Serbia.
Form A now matters only for countries remaining on the USTP list. These are primarily the least developed states of Africa, parts of Latin America, and Oceania. The applicable rules were approved by EEC Council Decision No. 60 dated June 14, 2018, as amended by Decision No. 49 dated May 14, 2024.
| Form | Regime | Countries of Origin | Benefit |
|---|---|---|---|
| ST-1 | CIS FTA | Uzbekistan, Tajikistan, Moldova, Azerbaijan, and other CIS countries outside the EAEU | Zero or reduced duty |
| EAV | EAEU-Vietnam FTA | Vietnam | Zero or reduced duty (per Agreement schedule) |
| Form A | EAEU USTP | Remaining developing and least developed countries (LDCs) | 25% reduction (developing) or 0% (LDCs) |
| ST-3 | EAEU-Iran FTA | Iran | Per Agreement schedule |
ST-1 and Trade with CIS Countries
The Agreement on the Rules for Determining the Country of Origin of Goods in the Commonwealth of Independent States (CIS) dated November 20, 2009 (the 2009 Agreement) governs preferential trade between Commonwealth states. For pharmaceutical and medical importers, this primarily means shipments from Uzbekistan, Tajikistan, Moldova, and Azerbaijan.
The ST-1 certificate is issued by the authorized body of the exporting country, typically the local Chamber of Commerce and Industry (CCI). Validity: 12 months from the date of issuance.
Three issues most commonly lead to a preference denial.
Direct shipment. Goods must travel directly from the country of origin to the destination country. Transit through third countries is permitted only under customs supervision. If cargo was stored at a warehouse in an intermediate country without customs oversight, this constitutes a violation of the direct shipment rule, and the preference may be revoked.
Weight discrepancy. The gross weight shown in the certificate must match the shipping documents exactly. Even a minor difference — a few kilograms in a large consignment — is enough to raise doubts about the identity of the goods. Customs may request verification.
Verification delay. When a customs authority doubts the authenticity of a certificate, it sends a verification request to the authorized body of the exporting country. Under the 2009 Agreement, the response window is 6 months. If no reply arrives within 3 months of a follow-up request, customs may definitively deny the preference. The importer then receives a demand for additional duties six months after import — long after the goods have been sold.
In government procurement, the rules are different. A certificate issued for customs clearance is not the same as a certificate needed to participate in tenders. Federal Laws No. 44-FZ and No. 223-FZ impose separate requirements: dedicated Regulations of the CCI of the Russian Federation, localization expert assessments, and local-content cost thresholds. Any company planning to bid on state contracts with goods from CIS countries must run a parallel origin audit against both sets of criteria.
EAV — The Certificate for Vietnamese Goods
The EAEU-Vietnam Free Trade Agreement was signed on May 29, 2015 and has been in force since October 5, 2016. It was the first FTA concluded on behalf of the EAEU as a single entity, rather than by individual member states. Under the Agreement, roughly 90% of tariff lines on both sides fall under duty reduction or elimination once all transition periods expire.
Importing goods from Vietnam into the EAEU requires a Form EAV certificate. On the Vietnamese side, it is issued by the Ministry of Industry and Trade of Vietnam (MoIT) or organizations authorized by MoIT. An important distinction: VCCI (the Vietnam Chamber of Commerce and Industry) issues non-preferential certificates (Form B). Presenting a Form B instead of EAV automatically results in a preference denial.
An electronic data exchange system for issued certificates operates between the EAEU and Vietnam. Russian customs can verify online whether a given certificate is registered in the MoIT database. Any manual corrections to a paper certificate are detected immediately: if a change is not reflected in the electronic database, verification fails at once.
This leads to a practical rule: check the certificate before shipment and ask the Vietnamese supplier to confirm that the data has been correctly uploaded into MoIT’s national database.
Form A After 2021 — Who Still Needs It
After the 2021 reform, 29 developing countries and most least developed countries remained on the USTP list. The Rules approved by EEC Council Decision No. 60 dated June 14, 2018 (as updated by Decision No. 49 dated May 14, 2024) continue to apply to them.
Decision No. 49 introduced two changes. It permanently established the option of presenting a copy of the certificate to claim a preference. Previously this was a temporary allowance. An importer can now claim the benefit based on a copy, keeping the original on file in case it is later requested. The process of exchanging specimen stamps and signatures between EAEU customs services and USTP beneficiary countries was also simplified. The absence of current specimens in the Federal Customs Service (FCS) database had previously been an automatic ground for rejection.
Technical requirements for Form A remain strict: the form must be completed in English or French, validity is 12 months, and the origin criterion code must be entered in Box 8.
Origin Criteria — What Must Be Demonstrated
Any preferential regime requires that the goods satisfy origin criteria. There are only two, but the entire logic of working with a supplier depends on which one applies.
Wholly obtained goods. Minerals, agricultural produce, goods made entirely from local raw materials with no foreign components. For most industrial and pharmaceutical goods, this criterion does not apply.
Sufficient processing. Where foreign materials are used in production, goods are considered to originate in the country of processing if one of three conditions is met: the HS code (Commodity Nomenclature for Foreign Economic Activities, CN FEA) changes at the four-digit level compared to the codes of the foreign materials used; the share of foreign raw materials stays within the allowed limit (typically not exceeding 50% of the ex-works price); or specified manufacturing operations are carried out.
For pharmaceutical substances, this is a particularly sensitive point. Synthesizing a substance in the country of origin typically produces a change in HS code. Packaging or portioning an already finished substance does not. This needs to be verified for each specific commodity item before the contract is signed.
The «Third-Party Invoicing» Risk
A common scenario: the manufacturer is in Vietnam, the contract is with a trader in Hong Kong, and the trader issues the invoice. Customs spots a discrepancy — the certificate names the Vietnamese factory as the exporter, while the invoice names a third-country company as the seller.
Third-party invoicing is not a violation in itself. But it must be explicitly stated in the certificate: the remarks field must carry a «Third Party Invoicing» note with the name and address of the third-country seller and its invoice number. If that entry is absent and the exporter and the seller do not match in the customs declaration, that is a formal ground for refusal.
What to Do
Run a tariff audit. For each commodity code, check the CCT rate and whether a preferential agreement exists with the supplier country. The zero duty is already built into the tariff — if the country is on the list, the work should start now.
Identify the correct certificate form. Make sure you are requesting the right document: EAV from Vietnam is issued by MoIT; ST-1 is issued by the CCI of the exporting country; Form A is relevant only for countries still on the USTP list after 2021.
Agree on a draft certificate before shipment. Ask the supplier for a draft and check it against the commercial invoice and packing list. Gross weight, number of packages, and invoice numbers must match to the last character.
Secure supplier obligations in the contract. Include a clause requiring the supplier to provide an original certificate in the prescribed form, and making them financially liable for errors that result in additional duty assessments.
Plan the route with the direct shipment rule in mind. If transit is unavoidable, arrange for the cargo to be stored under customs supervision in the intermediate country and obtain a certificate of non-manipulation.
Errors in certificates of origin rarely surface immediately. Customs may release the goods, then send a verification result six months later demanding additional payment. That is precisely why this cannot be left to a broker at the airport. It starts at the negotiating table with the supplier.
Regulatory Base:
1. Decision of the Board of the Eurasian Economic Commission No. 36 dated April 19, 2016 «On Approval of the List of Goods in Respect of Which Tariff Preferences Are Not Granted upon Import into the EAEU Customs Territory from the Socialist Republic of Vietnam»
2. Agreement on the Rules for Determining the Country of Origin of Goods in the Commonwealth of Independent States, dated November 20, 2009
3. EEC Council Decision No. 60 dated June 14, 2018 «On Approval of the Rules for Determining the Origin of Goods from Developing and Least Developed Countries» (as amended by EEC Council Decision No. 49 dated May 14, 2024)
4. EEC Council Decision No. 17 dated March 5, 2021 «On Amending Decision of the Customs Union Commission No. 130 dated November 27, 2009» (entered into force October 12, 2021)
5. Free Trade Agreement between the Eurasian Economic Union and its Member States and the Socialist Republic of Vietnam, dated May 29, 2015 (entered into force October 5, 2016)