The purpose of the changes is to strengthen "end—to-end control" over the legitimacy of conformity assessment documents (certificates and declarations), especially in situations where testing laboratories and authorities from other EAEU states are involved in the chain, and importation into the Russian Federation is already based on ready-made documents.
What is changing in the registry of certificates and declarations
An interstate verification mechanism has been added to the rules for maintaining the unified register (Resolution No. 1856): the national accreditation body receives the right to send a request to the national accreditation body of another EAEU state in order to confirm the accreditation status of the laboratory and information about the test protocol/report on the basis of which the certificate was issued.
The practical meaning for importers is simple: "there is paper, but the origin of the protocol is questionable" is no longer a working scenario. Previously, risks often surfaced after the fact (on the market or during inspections), now there is a direct channel for confirming the original source of tests through accreditation.
Customs has become a source of grounds for suspension
The most sensitive issue for foreign economic activity is changes in the rules under Resolution No. 936. The cases when the national accreditation body can suspend the declaration of conformity on the territory of the Russian Federation upon receipt of information from customs authorities have been expanded. Among the grounds are the import of products according to the declaration, where there is no information about the test reports (if required by the scheme), the identification of inconsistencies in safety indicators based on the results of the customs examination, as well as the lack of confirmation of the import of samples / samples for testing.
The verification tool "through the EAEU" is fixed separately: if the national accreditation body of a member State reports that the protocol referred to in the declaration has not been issued, this also becomes the basis for decisions in the Russian Federation.
A "systemic measure" against mass dubious documents
The resolution also introduces a stricter logic for documents registered in other EAEU countries by one body: if declarations of such origin have been suspended 3 or more times during the year for established reasons, a "package measure" is possible — the termination of all declarations registered by this body on the territory of the Russian Federation for the next 12 months (according to the rules, described in the updated version).
What to expect for a business: consequences and recommendations
For importers, this means an increased role of pre-shipment control.:
- Check the completeness of the evidence base: test reports, information about the laboratory, the correctness of links to documents specifically for your batch / product.
- Separate the responsibilities in the contract: who is responsible for the reliability of the protocols and the right of use, who bears the costs of suspension / invalidation.
- Prepare for stops at the border: if customs records discrepancies or "empty" references to tests, the risk of documents being suspended becomes operational rather than theoretical.
- Special attention is paid to products with frequent model/batch updates (electronics, equipment, components): this is where errors in the evidence base occur more often.
Resolution No. 87 is not "about bureaucracy", but about increasing the cost of errors in conformity assessment. From February 7, 2026, imports with "conditional" declarations and protocols without a real source will become much more risky, both financially and in terms of delivery time.
