G/TBT/W/660  
 
18 July 2019  
(19-4782) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
RUSSIAN FEDERATION - FEDERAL LAW NO 487 -FZ, PROVIDING A FRAM EWORK FOR 
COMPREHENSIVE USE OF  SPECIAL LABELLING A ND TRACEABILITY OF G OODS AND 
DECISION NO. 792 -R SPECIFYING THE GOODS TO WHICH LABELLING W ILL APPLY  
AND THE DATES OF INT RODUCTION OF THE MANDATORY LABELLING  
STATEMENT BY THE EUR OPEAN UNION TO THE C OMMITTEE ON TECHNICA L BARRIERS TO TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 17 July 2019, is being circulated at the request of the delegation 
of the European Union . 
 
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1.  On 28 April 2018 the Russian Government adopted decision No. 792-R, listing goods which will 
be subject to mandatory marking, along with the dates of introduction of these labelling 
requirements for each product category. It will cover tobacco, per fumes, tyres, different categories 
of clothing, footwear, cameras, and pharmaceutical products.  
2.  Though we commend the Russian government in its efforts to tackle counterfeiting, this measure 
includes technical regulations and will have a significant impac t on imports from the EU and from 
other WTO members to Russia. According to the Decision of 1995 of the TBT Committee, "Members 
are obliged to notify all mandatory labelling requirements that are not based substantially on a 
relevant international standard  and that may have a significant effect on the trade of other 
members ". Therefore, this measure should have been notified under the TBT Agreement before its 
adoption to give the opportunity to other WTO Members to provide their comments and allow 
sufficien t time for industry to adapt. The European Union would therefore like to urge the Russian 
Federation to notify this measure in accordance with the TBT Agreement.  
3.  Furthermore, the European Union would like to request details on the exact procedure to obtai n 
the mandatory labels. The requirements and processes for now remain unclear, in particular for 
imported products, which is causing EU industry difficulties in implementing necessary changes. The 
information to be included in the label should be clarified  as soon as possible and the equipment 
necessary for code identification should be made swiftly available to importers.  
4.  The Russian government adopted Resolution No . 515 on 26 April 2019 on the "marking of goods 
subject to mandatory labeling by means of id entification". Of course this measure also falls within 
the scope of the TBT Agreement and needs to be notified to the WTO, to open the period for 
comments. In accordance with the TBT Agreement, sufficient time shall be provided to industry to 
adapt to the  requirements necessary for placing products on the market of the Russian Federation, 
which is in general 6 months.  
5.  Taking into account that such requirements are still being developed, the European Union 
requests an adaptation of the deadlines for impleme ntation, especially for products sup posed to be 
labelled already in 2019, i.e. tobacco on 1 July 2019, footwear on 1 July 2019 (possibly postponed 
to 1 March 2020) and several other categories on 1 December 2019 including perfumes, tires and 
selected cloth es (shirts, coats, jackets) cameras.  Sufficient time needs to be given to ensure that all 
products to be placed on the market of the Russian Federation can comply. It can take long for a 
product to reach its final consumer, meaning that companies have to i ntroduce necessary changes 
along their chain of production months before the date of implementation, which is a particu larly a G/TBT/W/660  
 
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  concern for current stocks. In addition, introducing these changes ahead of the implementation date 
is difficult, as crucial info rmation on the exact requirements is still lacking.  
6.  The EU also has concerns on the proportionality of the measure: individual labelling and 
registration creates costs and burden. This may be justified for some products of high value and 
with a high recor d of counterfeit or tax evasion. However, it seems more trade -restrictive than 
necessary in the case of lower value products without such a negative record, such as towels and 
bed linen, which should comply with the novel labelling requirements already in 2019.  
7.  We ask the Russian Federation to take into consideration the European Union 's comments, to 
ensure that the implementation of this measure is not unnecessarily  trade -restrictive, in accordance 
with the WTO TBT Agreement.  
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