EAEU certificates and declarations of conformity can be issued in any member state — Russia, Kazakhstan, Belarus, Kyrgyzstan, or Armenia — and are valid across the entire union. Many companies shipping to Russia choose to certify in countries other than Russia because it is often more simple.
This has worked without issues for most companies. However, a recent regulatory change introduces a specific risk for those whose products are destined for the Russian market.
On February 6, 2026, the Russian Government issued Decree No. 87, which amends the rules for suspension and termination of certificates and declarations of conformity. The decree entered into force on February 7, 2026.
The key change is that Russian authorities now have an explicit mechanism to suspend the validity in Russia of individual conformity documents issued by certification bodies in other EAEU member states. The documents themselves remain valid in all other EAEU countries — they are only suspended on the territory of Russia.
The Russian national accreditation body can suspend a specific certificate or declaration issued in another EAEU country if Russian customs reports that product entered Russia with a conformity document but there are no test reports or laboratory protocols to support it, if customs expertise finds that the product does not meet the safety requirements of the applicable EAEU technical regulation, if there is no evidence that product samples were imported for testing purposes, or if the accreditation body of the issuing EAEU country confirms that the test report referenced in the conformity document was never actually issued by the laboratory. In these cases, the specific conformity documents in question are suspended.
There is also a cumulative mechanism. If a certification body accumulates three or more such suspensions within one year, the Russian accreditation body can block that body from having any new certificates or declarations recognized on the territory of Russia for the following 12 months. This does not retroactively invalidate previously issued documents — it means that any conformity documents issued by that body after the decision date will not be accepted in Russia during this period.
One aspect of the problem is the lack of visibility, as there is no public information about how many suspensions any given certification body has accumulated and no registry of ongoing investigations. A company choosing a certification body has no way to check whether that body is one suspension away from being blocked in Russia, putting their planned certification at risk.
For companies shipping to Russia, certifying in another EAEU country is cheaper but carries a risk: individual conformity documents can be suspended if supporting evidence is missing, and if the certification body is blocked, any new documents from that body will not be accepted in Russia. This can happen regardless of whether the company itself did everything correctly. Certifying in Russia is more expensive but eliminates this specific risk entirely, since Russian-issued documents are not subject to this cross-border mechanism.
For companies not shipping to Russia, this change has limited practical impact. Enforcement and market surveillance in other EAEU countries are considerably less strict, and conformity documents are rarely challenged.
Separately, Kyrgyzstan has begun testing a new "Single Window" registry system, similar to Russia's FGIS. Certification bodies will be required to upload test reports and customs cargo declarations to the government platform, as well as factory inspection documentation, with annual surveillance records expected to follow . This means the procedural differences between certifying in Russia and certifying in Kyrgyzstan are gradually narrowing — the list of required documents is growing, and the opportunities to reduce turnaround times are disappearing.
Government Decree of the Russian Federation No. 87, dated February 6, 2026. Entered into force on February 7, 2026.
