G/TBT/W/634  
 
9 April 2019 
(19-2262) 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  
6 AND 7  MARCH  2019 
The following communication, dated 5 April  2019, 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 European Union submitted detailed comments to Russia at the time, and has since repeatedly 
asked for updates on the status of the measure and whether the EU's comments had been taken 
into consideration.  Despite these update requests, Russia did not inform us of any developments on 
the measure, until we were surpris ed to see it officially annouced in December 2018 that a new 
version of the measure had been adopted.  
2.  As this was done without renotifying the revised text and c onsidering the trade implications of 
this regulation , we would like to ask Russia to comply with WTO transparency provisions and notify 
the revised  text t hrough the TBT Committee , in order to give other WTO members the opportunity 
to make comments. The EU would also like Russia to clarify the implementation date.  
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 TRIPS , as some of these provis ions raise 
serious concerns for the EU:  
• The agreement notably inappropriately uses certain EU geographical indications which 
could raise concerns for the protection of these terms in accordance with WTO TRIPS rules. 
This is the case for products reffered t o as "champagne ", "calvados " and "cognac ".  
• The regulation contains a number of problematic definitions of products which do not 
recognize normal production practices accepted in the EU, which could lead to trade 
disruptions for the categories of products concerned  (for instance, the EU disagrees with 
the proposed definition of "table wine ", 'wine with protected geographical indication' and 
'wine with protected designation of origin '. Also, the requirement that bottling must take 
place within the area of an y geographical indication seems problematic. ).  
4.  These  crucial issues related to Geographical indications should be discussed in the TRIPS Council.  
5.  The European Union would also 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 EU , which are  in line with the recommendations 
of the International Organization of Vine and Wine  (OIV), of which Russia is Mem ber. The 
application of these requirements would represent an obstacle for the importation of these 
products.  G/TBT/W/634  
 
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  • The EU is also 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 storage conditions.  
• 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 conduct ed by 
a state entity  and covers a wide range of requirements such as documentation and 
laboratory analysis, which represents a disproportionate burden and cost for producers. 
We would like to receive clarification how the conformity procedure will apply to  imported 
products and whether EU accompanying document s will be considered as sufficient to 
establish the compliance of EU products with the notified technical regulation.  
6.  The European Union would like to ask Russia to take these comments into considerat ion and 
renotify the new version of the measure, under the TBT agreement as well as under the TRIPS 
agreement.  
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