G/TBT/W/686  
 
25 November 2019  
(19-8002) 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 INTRODU CTION OF THE MANDATORY LABELLING  
STATEMENT BY THE EUROPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
13 – 15 NOVEMBER  2019 
The following communication, dated 13 November  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 № 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 
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 sta ndard 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 
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 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, deadlines, references to legislation, information contact 
points, Q&A part where the most frequent issues wou ld be explained, etc. Such a guideline would 
significantly facilitate situation for majority of economic operators, both European and Russian.  
4.  The Russian government adopted Resolution No 515 on 26 April 2019 on the "marking of goods 
subject to mandatory l abeling 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 i ndustry 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 th e deadlines for implementation, especially for products supposed to be 
labelled already in 2019, i.e. tobacco on 1st July 2019, footwear on 1st July 2019 (postponed to 1 
March 2020) and several other categories on 1st December 2019 including perfumes (sugg ested to 
be delayed to 1 July 2020), tires (suggested to be postponed to 1 November 2020) and selected 
textiles (shirts, coats, jackets, bed -linen-suggested to be postponed to 1 July 2020) cameras 
(suggested to be postponed to 1 June 2020).  G/TBT/W/686  
 
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  6.  Even though the re have been suggested postponements (legislative procedures ongoing) for 
different categories, these largely seem to be linked to the system not yet being operational. 
Operators need additional time to ensure that all products to be placed on the market o f 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 particularly co ncern for current stocks. In addition, introducing 
these changes ahead of the implementation date is difficult, as crucial information on the exact 
requirements is still lacking.  
7.  The EU also has concerns on the proportionality of the measure: individual l abelling 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. However, it seems more trade -restrictive than 
necessary in the case of lower value products with out such a negative record, such as towels and 
bed linen.  
8.  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 t he WTO TBT Agreement.  
 
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