G/TBT/W/725  
 
10 March  2020 
(20-1843) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
RUSSIAN FEDERATION - DRAFT TECHNICAL REG ULATION ON ALCOHOL D RINKS  
SAFETY (PUBLISHED ON  24 OCTOBER 2011)  
STATEMENT BY THE EUROPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
26 – 27 FEBRUARY  2020 
The following communication, dated 9 March  2020, is being circulated at the request of the 
delegation of the European Union . 
 
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1.  In 2012, the Russian Federation notified a draft technical regulation on alcohol products safety. 
The EU submitt ed detailed comments to Russia, and has since asked for updates on the status of 
the measure and whether the EU 's comments had been taken into consideration. Despite these 
requests, Russia did not inform us of any developments on the measure, until it offi cially announced 
in December 2018 that a new version of the measure had been adopted.  
2.  In light of transparency and considering the trade implications of this regulation, we would like 
to ask Russia to notify the revised text to the TBT Committee.  
3.  The technical regulation also contains provisions covered by the Agreement on trade -related 
aspects of intellectual property rights. The EU would like to invite Russia to notify the regulation to 
the Council for TRIPS, in accordance with Article 63.2 of the TR IPS so that the discussion can take 
place there, as some of these provisions, in particular impacting geographical indications, raise 
serious concerns for the EU.  
4.  The European Union would like to express the following concerns with the new version of the 
measure:  
• Physical and chemical requirements laid down in the regulation in some cases contain 
more stringent limits than those set in the recommendations of the OIV, of which Russia 
is Member. The application of these diverging requirements would represent  an obstacle 
for the importation of these products.  
• The EU is concerned by the mandatory labeling requirements set out in the regulation, 
which are not in line with international practice, by requiring for example, information such 
as date markings and sto rage conditions The EU would like to ask Russia to refer to CODEX 
standards as regards the indication of date markings and storage conditions, which are 
strictly linked to each other . Could Russia confirm that the use of stickers is allowed, 
according to C ODEX STAN 1 -1985?  
• Finally, alcoholic beverages must prove conformity with the rule set out in the regulation 
in order to be marketed in the EAEU territory. The conformity assessment is conducted  by 
a state entity  and covers a wide range of requirements suc h as documentation and 
laboratory analysis, which represents a disproportionate burden and cost for producers. 
Could you please confirm that the conformity procedure will apply to imported products 
and that EU accompanying documents will be considered as s ufficient to establish the 
compliance of EU products with the notified technical regulation?  G/TBT/W/725  
 
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  • Moreover, it appears that Russia has adopted a measure "Federal Law N ° 468 of 
27 December 2019 on wine making and wine growing in the Russian Federation" . The 
meas ure seems to include technical requirements applicable to wine. Some of them 
coincide with the technical requirements set out in the EAEU TR on alcoholic products, but 
some do not. For example the federal law states that for wine the content of ethyl alcoh ol 
must be between 7.5 to 18%, whereas the EAEU TR sets the range between 8.5 to 18%. 
Therefore the EU would like to ask how the Russian Federal Law and the EAEU TR relate 
with regard to mandatory technical requirements applicable to wine; whether 
discrepa ncies between the EAEU TR and the Russian Federal Law are intended or 
accidental; whether the EAEU TR is directly applicable in Russia or not and, if not, whether 
Russia intends to adopt similar national measures applicable to other alcoholic products 
than wine covered by the EAEU TR but not by the above referenced Federal Law.  
5.  The European Union would like to ask Russia to take these comments into consideration and to 
renotify the new version of the measure as well as to notify the new wine measure, under the TBT 
agreement as well as under the TRIPS agreement.  
 
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