it is mandatory for foreign manufacturers with no Russian representative to have an official representative company that is registered within Customs Union and will be responsible for quality and conformity according to the TR regulation of products sold within the CU market. Manufacturers without representative face problems in obtaining certification for serial production valid for more than 1 Year. A company acting as representative of the manufacturer is an official applicant to the conformity assessment procedure and is shown on all Certificates and Declarations. There is a risk that a foreign manufacturer becomes fully dependent on its representative, because legally seen this company is the „owner“ of Certificates.
Providing a serious representative to our clients is one of our strongest advantages. Our Russian legal team of 3 Russian lawyers, specializing on Certification Legislation, will be happy to support our clients in all requests.
Significant changes from July 2018 and its impact: Starting from July 2018 major changes in Russian Law have been introduced. The new regulation is essentially based on creating transparency in the whole Certification System. The main reason of changing the rules was to hold the producers responsible for testing their own products and take away these activities from Russian importers.
Continual control by the government causes delays in the whole Certification process. The Russian customs authorities introduced a new procedure of pre-customs release. This is a kind of a confirmation from the Certification Body, which is temporarily sufficient for the import of goods in Russia, as long as the issuance of the certificates by the Certification Body is pending.
The goods will be “conditionally” released at customs. However, there is an obligation of providing EAC Certificates or Declarations to the Russian customs authority within 45 days. Goods released “conditionally” are prohibited for transfer to third parties, including their sale in any other way.