G/TBT/W/639  
 
9 April 2019 
(19-2265) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
RUSSIAN FEDERATION — FEDERAL LAW N O. 487-FZ, PROVIDING A  FRAMEWORK 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 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.  On 28 April 2018 t he 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, perfumes, 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  
include s technical regulations  and will have a sign ificant impact  on imports from the EU and from 
other WTO members to Russia . According to the Decisi on of 1995 of the TBT Committee, "Members 
are obliged to notify all mandatory labelling requirements that are not based substantially on a 
relevant internati onal 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 al low 
sufficient 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 obtain 
the mandatory labels. The requirements and processes for now remain unclear , in particular for 
imported products, which is causing EU industry difficulties in im plementing necessary changes. The 
information to be included i n the label  should be clarified as soon as possible and the equipment 
necessary for code identification should be made swiftly available to importers.  
4.  Russia seems to be working on a project of governmental resolution concerning "the product 
identification labelling system and traceability of goods movement " which would include a regulation 
on the "marking of goods subject to mandatory labeling by means of identification ". Of course this 
draft me asure 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 plac ing 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 implementation, especially for products  supossed to be 
labelled already in 2019, i.e. tobacco on 1  March 2019, footwear on 1 July 2019 and several other 
categories on 1 December 2019.  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 introduce necessary changes along thei r chain 
of production months before the date of implementation, which is a particuarly a concern for current G/TBT/W/639  
 
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  stocks. In addition, introducing these changes ahead of the implementation date is difficult, as crucial 
information on the exact requirements is s till 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 record of counterfeit or tax evasion. Howev er, 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 implementation of this measure is not unecessarily trade -restrictive, in accordance with the 
WTO TBT Agreement.  
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