On March 12, 2022, the Decision of the Government of the Russian Federation No. 353 "On peculiarities of permit issuing activity in the Russian Federation in 2022" was published and immediately entered into force.
The measures stipulated in this document are aimed at reducing the costs associated with the passage of permit procedures. In total, the Decision covers more than 120 types of permits in different sectors, including agriculture, industry, trade, etc.
Peculiarities of conformity assessment of products
One of the most important areas covered by this Decision is the sphere of conformity assessment of products on which we will take a closer look.
Annex 18 to Decision No. 353 defines the peculiarities of conformity assessment of products to the requirements of technical regulations, as well as to the Federal Law No. 184-FZ "On technical regulation" dated December 27, 2002, during the period of temporary restrictions.
First, the document stipulates the simplifications as to the carrying out the annual quality control of certified products circulating on the territory of the Russian Federation in 2022 in the form of a remote analysis of the state of production. Tests on product samples may also be conducted instead.
In addition, the certification body has the right to decide to postpone the quality control, which is scheduled in 2022, for up to 6 months.
As for the conformity assessment documents (EAC certificates and EAC declarations) that expire between March 12, 2022, and September 1, 2022, they are extended for an additional 12 months.
Production and release of products using current documents of conformity with a prolonged validity will be possible without additional checks.
The document also indicates that when products are imported into the territory of Russia, it is sufficient to provide information about the documents of conformity at the customs, the originals are not required.
The groups of products allowed to pass through customs without authorization documents (information about them) are:
- spare parts that are imported for maintenance or repair of previously released products in Russia;
- components, elements, raw materials or materials for the manufacturing of products in Russia;
- single items for the own needs.
EAC marking
The Decision No. 353 also introduces simplifications in terms of product labeling. Until March 1, 2023, it is allowed to import goods intended for sale only within Russia without labeling established by mandatory requirements, including the EAC mark. Labeling is required prior to the sale of products to the consumer.
Simplified form of conformity assessment
Some of the important changes concern the simplification of forms of conformity assessment of products.
Starting from March 21, 2022, to September 1, 2022, it will be possible to replace product certification and declaration by schemes involving an accredited testing laboratory with a declaration based on their own evidence of product safety. This will be possible in the following cases:
- Conformity assessment is required for a batch of products or a single product;
- Only legal entities or individual entrepreneurs registered in Russia can be applicants;
- A set of documents is required: the contract / delivery contract (copy) and shipping documents identifying the batch / single product; description of the technical solutions adopted and the results of the risk assessment, confirming compliance with mandatory requirements; list of standards (if applicable); documents and information that served as the basis for the declaration of conformity, made in a foreign language with a translation into Russian (except for attachments to the test protocols);
- The declaration of conformity must be registered by the applicant on the portal of the "Rusaccreditation";
- The period of validity of the declaration of conformity is 6 months from the date of registration in the register of the "Rusaccreditation";
- Products do not need to have the EAC marking.
The list of products for which a simplified declaration of conformity cannot be issued will be approved by the Russian Ministry of Industry and Trade.
In the future, certification and declaration of products with the participation of accredited testing laboratories may be carried out with sampling from the batch of products imported into the territory of Russia under the simplified declaration of conformity.
Measures concerning GLN
The rule of indication of the GLN number or other individual identifier that allows the automatic identification of the address of production for certification and declaration of conformity of products has been suspended until March 1, 2023, by the Decision No. 353.