G/TBT/W/727  
 
10 March  2020 
(20-1849) 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 MAN DATORY  LABELLING  
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.  On 28 April 2018 the Russian Government adopted decision N° 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.  The EU has very serious concerns on the proportionality of the measure: individual labelling and 
registration creates significant burden and cost, well beyond the cost  of the individual labels. This 
may be justified for some products of high value and with a high record of counterfeit or tax evasion, 
such as tobacco products or furs. However, it seems more trade -restrictive than necessary in the 
case of lower value prod ucts without such a negative record, such as towels , bed linen or tyres.  
3.  Though we commend the Russian government in its efforts to tackle counterfeiting, this measure 
includes technical regulations and will have a significant impact 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 s hould have been notified under the TBT Agreement before its 
adoption to give the opportunity to other WTO Members to provide their comments and allow 
sufficient time for industry to adapt. The European Union would therefore like to urge the Russian 
Federat ion to notify this measure in accordance with the TBT Agreement.  
4.  In order to comply with the obligation that measures shall not be more trade -restrictive than 
necessary to achieve their legitimate objective, unique identification and traceability should on ly 
apply to categories of products of relatively high value, and for which evidence of significant levels 
of counterfeit or tax avoidance is available. The EU requests Russia to apply the requirements in a 
much more selective, targeted way, than it is curr ently planned.  
5.  Furthermore the European Union would like to request the Russian Federation authorities to 
prepare a comprehensive guideline providing exhaustive information on technical details such as: 
timetable of goods to be labelled until 2024, deadlin es, references to legislation, information contact 
points, Q&A part where the most frequent issues would be explained, etc. Such a guideline would 
significantly facilitate situation for majority of economic operators, both European and Russian.  
6.  The Russian  government adopted Resolution No 515 on 26 April 2019 on the "marking of goods 
subject to mandatory labeling by means of identification" . 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 G/TBT/W/727  
 
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  adapt to the requirements necessary for placing products on the market of the Russian Federation, 
which is in general 6 months.  
7.  Taking into acco unt that such requirements are still being developed, the European Union 
requests an adaptation of the deadlines for implementation, especially for products suposed to be 
labelled very soon. Some deadlines have been postphoned, but an unclear situation rem ains on the 
ground. Current deadlines seem to be the following:  
• Footwear - 1 March 2020  
• Perfumes and eau de toilette - 1 October 2020  
• Photo cameras - 1 October 2020  
• Tyres - 1 November 2020  
• Textiles - 1 January 2021  
8.  These postponements for different categories seem to be largely linked to the system not yet 
being operational. Operators need additional time 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 their chain of 
production months before the date of implementation, which is a particuarly concern for current 
stocks. In addition, introducing these changes in the production  cycle ahead of the implementation 
date is difficult, as crucial information on the exact requirements is still lacking.  
9.  We ask the Russian Federation to take into consideration the European Union 's comments, to 
ensure that the implementation of this measu re is not unecessarily trade -restrictive, in accordance 
with the WTO TBT Agreement.  
 
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