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 and because it is often more simple.
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 individual 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 specific 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. In these cases, the specific conformity documents in question are suspended.
There is also a cumulative mechanism. If a certification body accumulates three or more such suspensions within one year, the Russian accreditation body can block that body from having any new certificates or declarations recognized on the territory of Russia for the following 12 months. This does not retroactively invalidate previously issued documents — it means that any conformity documents issued by that body after the decision date will not be accepted in Russia during this period. This interpretation has been confirmed by the Federal Accreditation Service in its official clarification letter No. 1226-OG dated March 17, 2026.
As of April 2026, eight Kyrgyz certification bodies have been blocked in Russia under this mechanism:
In some cases, the blocking was applied retroactively. For example, documents issued by Eurasia Certificate were terminated effective December 26, 2025 — but the decision was only made public in mid-April 2026, nearly four months later. Companies that obtained conformity documents from that body during this period had no way of knowing about the issue and found their documents invalidated after the fact.
The problem is not the rule itself but the lack of visibility. There is no public information about how many suspensions 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 being blocked in Russia. And as the table above shows, even when a body is blocked, the effective date can precede the announcement by months, leaving companies exposed without warning.
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.
For companies shipping to Russia, certifying in another EAEU country is cheaper but carries a risk: individual conformity documents can be suspended if supporting evidence is missing, and if the certification body is blocked, any new documents from that body will not be accepted in Russia. This can happen 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.
Government Decree of the Russian Federation No. 87, dated February 6, 2026. Entered into force on February 7, 2026.
Updated: April 27, 2026
