EAEU certificates and declarations of conformity can be issued in any member state — Russia, Kazakhstan, Belarus, Kyrgyzstan, or Armenia — and are valid across the entire union. Many companies choose to certify in countries other than Russia both to respect the sanctions against Russia, and because it is often more simple and less expensive.
This has worked without issues for most companies. However, a recent regulatory change introduces a specific risk for those whose products are destined for the Russian market.
On February 6, 2026, the Russian Government issued Decree No. 87, which amends the rules for suspension and termination of certificates and declarations of conformity. The decree entered into force on February 7, 2026.
The key change is that Russian authorities now have an explicit mechanism to suspend the validity in Russia of conformity documents issued by certification bodies in other EAEU member states. The documents themselves remain valid in all other EAEU countries — they are only suspended on the territory of Russia.
The Russian national accreditation body can suspend a certificate or declaration issued in another EAEU country if Russian customs reports that product entered Russia with a conformity document but there are no test reports or laboratory protocols to support it, if customs expertise finds that the product does not meet the safety requirements of the applicable EAEU technical regulation, if there is no evidence that product samples were imported for testing purposes, or if the accreditation body of the issuing EAEU country confirms that the test report referenced in the conformity document was never actually issued by the laboratory.
If a certification body accumulates three or more such suspensions within one year, the Russian accreditation body can terminate the validity in Russia of all certificates and declarations issued by that body for the following 12 months. The suspensions do not need to be related to each other — they can come from different products, different importers, and different projects. The count is against the certification body, not against any individual company.
The problem is not the rule itself but the lack of visibility. There is no public information about how many strikes any given certification body has accumulated and no registry of ongoing investigations. A company choosing a certification body in Kazakhstan or Kyrgyzstan has no way to check whether that body is one suspension away from a full shutdown in Russia.
The triggers for suspension are also broader than outright fraud. For example, if an importer in Russia cannot produce documentation requested by customs — because files were lost or there was an administrative error — this can count against the certification body that issued the document. The body itself may not even be at fault. Three Kyrgyz certification bodies have already had their certificates suspended, which has been officially published. Whether and when other bodies will be affected is unknown.
For companies shipping to Russia, certifying in another EAEU country is cheaper but carries a risk that the conformity document could be suspended due to the certification body's track record, regardless of whether the company itself did everything correctly. Certifying in Russia is more expensive but eliminates this specific risk entirely, since Russian-issued documents are not subject to this cross-border mechanism.
For companies not shipping to Russia, this change has limited practical impact. Enforcement and market surveillance in other EAEU countries are considerably less strict, and conformity documents are rarely challenged.
The decision comes down to a cost-risk tradeoff. The risk may be small, but it cannot be assessed or mitigated from the outside, which is what makes it difficult to manage.
