28.09.2026 Regulation #EAEU #Russia #Import #Trade agreements

EEC finds Russia's certificate suspension rules breach EAEU law, entry delayed

The Board of the Eurasian Economic Commission ruled on September 8, 2026, in Decision No. 118 "On the Russian Federation's compliance with obligations within the functioning of the internal market of the Eurasian Economic Union," that Russian rules allowing authorities to suspend, terminate and invalidate conformity certificates and declarations issued by bodies of other EAEU member states do not comply with Union law. The decision was due to take effect 30 calendar days after its official publication on September 10, 2026, but EEC Notice No. 2 of September 24, 2026 suspended its entry into force — at the proposal of Russian Prime Minister Mikhail Mishustin, pending review by the Eurasian Intergovernmental Council.

The EEC's objections to Russia's certification rules

At issue is Russian Government Resolution No. 936 of June 19, 2021: the EEC Board found that clause 281-1 of the Rules for Registration of Conformity Declarations and clause 141-1 of the Rules for Suspension of Conformity Certificates do not comply with Union law (Decision No. 118). These provisions allowed Russian bodies to suspend, terminate and declare invalid conformity documents issued by bodies in Armenia, Belarus, Kazakhstan and Kyrgyzstan (ppt.ru).

In practice, as a column on tks.ru describes, this was a "three suspensions" rule: once a certification body's certificates had been suspended three times within a year, all its subsequent certificates were declared invalid in advance. According to the columnist, the rule was applied to three Kyrgyz bodies from February 9, 2026, and the number later grew to six (tks.ru).

For producers in Armenia, Belarus, Kazakhstan and Kyrgyzstan

Until Resolution No. 936 is amended, the disputed rules remain in force — a Board decision obliges a state to fix its act but does not repeal it by itself (ppt.ru). Under Decision No. 118, Russia is to eliminate the non-compliance within 60 calendar days of the decision's entry into force and notify the EEC no later than 15 calendar days after that. The EEC also reminded Russia to comply with the EAEU Treaty when deciding to terminate all conformity documents registered by one body within 12 months of the last suspension decision (Decision No. 118).

Mishustin halted the decision's entry into force

According to EEC Notice No. 2, Decision No. 118's entry into force was suspended at the proposal of Mikhail Mishustin as a member of the Eurasian Intergovernmental Council, under clause 117 of the EEC Rules of Procedure and clause 30 of the Regulation on the EEC, pending the Council's review and its decision on the matter (EEC Notice No. 2). Ppt.ru also reports an application for repeal of Decision No. 118 filed with the Commission by Deputy Prime Minister Alexei Overchuk, and notes that Russia's current certificate-recognition procedure does not change while it is under review (ppt.ru).

Primary sources

This material is for information only and does not constitute legal advice or customs consulting. Verify changes against the primary sources before acting.