Starting 30 November 2025, amendments to Russian Government Resolution No. 936 come into force, introducing a new mechanism that allows Russian market surveillance authorities to suspend certificates and declarations of conformity (CoC/DoC) issued in other EAEU member states (Kazakhstan, Kyrgyzstan, Armenia, Belarus) and, where necessary, subsequently invalidate them within the territory of the Russian Federation.
Under the updated rules, Russian authorities may suspend the validity of foreign-issued CoCs/DoCs in cases where:
- evidence of non-conformity of the product is identified;
- the certificate holder or applicant fails to provide additional supporting documents upon request;
- the Federal Customs Service (FCS) reports imports of products accompanied by CoCs/DoCs without corresponding test reports registered in the system.
Information on any suspension decisions will be sent to:
- the Eurasian Economic Commission (EEC), and
- the market surveillance authority of the EAEU member state that originally registered the document.
Rosaccreditation will introduce a new section of its public registry, where all suspended and invalidated CoCs/DoCs issued outside Russia will be published.
Practical implication for exporters:
Companies supplying products to Russia while obtaining conformity documents in other EAEU countries should ensure strict compliance with the rules for importing samples for testing, maintain customs declarations for sample imports (DT, GTD), and keep copies of test reports available for inspection. Failure to do so may lead to suspension or invalidation of their conformity documents within the Russian market.
