In 2002, the Federal Law No. 184-FZ about "Technical Regulation" announced the beginning of significant changes in the system of products compliance test in Russia. Later, the Rostekhregulation (currently Rosstandart) released the new list of products subject to mandatory compliance test. This list has differentiated products whose conformity must be certified through the Certification GOST R and the Declaration GOST R. Since the enactment of the first Technical Regulations, product compliance can be checked according to GOST R or TR relevant requirements. Some TR provide compliance certification by the Declaration of Conformity. Thus, both systems GOST R and TR coexist with the possibility of compliance certification by the certificate or the Declaration.
It is crucial to note that the identification of products in Russia is performed in accordance with the Russian National Classifier OKP while foreign manufacturers indicate the code of harmonized customs nomenclature (HS) and it is controlled by Russian Customs .
The classifier of products of the Russian Federation (its initials: OKP) - is the Russian state national framework which belongs to the unique system of classification and technical, economic and social coding about products. In this system products are classified by their area of use.
In the practice of foreign trade, imported or exported goods are declared in accordance with Customs nomenclature of goods (NDP) contained in the Customs tariff.
It is made according to the international nomenclature of the Harmonized System (HS) for designation and Coding of goods which is not alphabetical but methodical. It takes into account:
- the product's origin (animal, vegetable, mineral)
- the constituent material of the commodity and sector of product use
- the industry which involves them
The NDP therefore allows us to give each product a designation and a code (12 digits plus a letter) that constitute "the tariff".
The organizing principle of OKP classifier is different from that of Customs Nomenclature of goods. This can create ambiguities when identifying a product.
OKP code operates both for the identification of products on the Russian market and for the local customs control. Its determination is therefore essential. It is done gradually. This research is sometimes difficult, even if only because the seller refuses to disclose the exact composition of the product to the buyer to protect its know-how. In case of doubt, the exporter has an opportunity to make a request to the Russian Scientific and Research Institute for Certification (VNIIS) to find out if there is a need for certification of the product in question which describes the product and which is accompanied by all relevant documentation and eventually by samples.
Exemption Letter is an informal document though recognized by the Russian Customs that presents the opinion of the official expert on the nature of product and its necessity for mandatory compliancy check. The Letter is useful during Custom clearance of your goods in Russia.
Scope and relevant products:
- products which have ambiguous identification by customs and according to the criteria GOST R or TR are concerned.
- products crossing the border as humanitarian aid.
- second-hand products that do not require mandatory compliance certificate.
The Letter of Exemption is also required by the RTN authorities in obtaining RTN Permit, according to the "Administrative Rules RTN (Rostekhnadzor)" issued on March 19, 2008 related to the list of documents constituting the file for obtaining RTN permits to use the equipment in the Russian territory.
In order to prove to the Russian customs that your products do not require mandatory compliance test, it is recommendedto the manufactureror its agent to obtain a letter of exemption confirming that fact.
Letter of Exemption
How to get it and applicable procedures
The official request to the Russian Institute of Scientific Research on Certification (VNIIS) accompanied by the following:
- copy of the delivery contract in Russia
- list of products
- technical description of products
- export certificate for second-hand goods or as a part of humanitarian aid
- legal proof of second-hand goods or humanitarian aid delivery
- advice on the identification of your products according to the classification criteria OKP
- compiling application file for the VNIIS
- obtaining the Letter of Exemption
Other additional certifications or registrations may be required for consumer products or equipment. Sometimes, obtaining them is prior to GOST R or TR compliance test: