Russia Decree No. 867: The 2026 Import Certification Rulebook

On July 10, 2026 the Russian government published Decree No. 867, which entered into force on August 9, 2026. It overhauls how conformity documents are checked at import for a list of more than 400 product codes — agricultural machinery, elevators and lifting equipment, tractors, radiators and heating equipment, refrigeration equipment, plus fireworks and pyrotechnics — while simultaneously extending simplified-document measures for other goods until September 1, 2027. If you ship these categories into Russia and Kazakhstan/Belarus (EAEU), the rule directly changes your pre-shipment checklist.

1. What Decree 867 changes

• Original documents at declaration: for the listed 400+ codes, the importer must present the original EAC certificate or declaration of conformity (not a copy or a letter of guarantee) when lodging the customs declaration.
• Proof of right of use: if the EAC certificate is held by the manufacturer or another company, the importer needs documentary proof it is entitled to use that certificate for its batch — typically an authorization/agency letter tied to the certificate.
• EAC marking before import: goods and their packaging must carry the EAC mark before crossing the border — customs now treats absence of marking as a conformity breach rather than a post-import labeling formality.
• Simplified rules extended for others: for products outside the list, the temporary simplified conformity procedure (declaration-based schemes with reduced paperwork) is extended to September 1, 2027.

2. Which products are affected

The controlled list centres on equipment categories where fake or invalid EAC certificates have been a recurring problem: agricultural machinery and attachments; tractors; elevators and lifting/hoisting equipment; heating radiators and heating equipment; refrigeration and cooling equipment; and fireworks/pyrotechnic articles. The detailed code list runs to 400+ HS codes and should be checked code-by-code against your invoice before production ships — a product whose name sounds generic (e.g. 'industrial fan') may fall under cooling/heating equipment depending on its exact code.

3. Shipper checklist before loading

1. Check every HS code on your invoice against the Decree 867 code list; flag controlled items before production finishes.
2. Verify the EAC certificate/declaration is valid, issued for the exact product model and manufacturer, and obtain the original (or certified copy accepted under the procedure).
3. If you are not the certificate holder, get the right-of-use letter from the certificate holder before the goods arrive.
4. Affix the EAC mark on products and packaging at the Chinese factory — do not plan to label after arrival; photograph marked goods for your records.
5. Send the full document set to your DDP forwarder/importer of record for pre-clearance review; document gaps found before loading cost days, gaps found at the border cost weeks and demurrage.

4. Common misconceptions

• 'The forwarder will sort out certificates at the border' — no: under Decree 867 the documents must exist and be valid before declaration; certificates cannot be backdated after goods arrive.
• 'EAC marking can wait until the warehouse' — no: marking is checked at import for the listed categories; unmarked goods are held.
• 'My product is not machinery, so it is safe' — check the codes anyway: radiators, cooling units and pyrotechnics sit in surprising places in industrial catalogues.

Decree 867 is not a trade barrier against Chinese goods — it is an anti-fraud measure aimed at fake certificates, and shippers with genuine EAC paperwork and pre-applied marking clear normally. The practical adjustment is moving certification work two weeks earlier in the order timeline.