noted that it would allow products in compliance with pre-2013 regulations to be marketed in the ECU until February 15, 2015.

Both Russia and the ECU have recently imposed new standards on alcoholic beverages in terms of labeling and warehousing requirements and conformity assessment procedures.<sup>31</sup> For example, labels on all alcoholic beverages must have an expiration date or indicate that the expiry date is unlimited if the storage conditions are observed. Under the Codex products containing more than 10 percent alcohol do not expire and are explicitly exempt from such requirements. Proposed amendments to the ECU technical regulations require that whiskey be aged no less than three years. In similar areas, Russia has liberalized recently, in November 2012, removing mandated aging of rums. However, it is said that Russian importers of U.S. products often complain that their import applications are denied.<sup>32</sup> Safety standards for clothing, footwear, and other products destined for use by children may exceed international norms and constitute an impediment to trade.<sup>33</sup> The ECU adopted its Technical Regulation TR 007/2011 on Safety of Products Intended for Children and Adolescents before Russia’s WTO accession. The regulation covers textiles, clothing, footwear, and other goods for children and adolescents, considering them as dangerous products that have a high risk for consumers. There are mandatory certification and labeling requirements and detailed requirements for documentation, all of which appear to exceed current international practices. EU exporters of such goods to Russia suggest that they are needlessly damaging to trade. For example, it is required that testing and conformity of such products be done exclusively in Russia. Another requirement is that the lining of children’s shoes cannot be made of artificial or synthetic materials. In non-Russian markets, it is considered that such lining can provide extra quality, for example insuring the breathability of the shoe. It is unclear what scientific information would be used to justify the requirement of non-artificial linings.

# **3.3 Sanitary and Phytosanitary Standards**

Harmonization of Russia’s SPS standards with the WTO’s is in process. As with TBT, SPS measures are now meant to be harmonized at the ECU level, a process that began in 2010, when the ECU was formed: The ECU agreements provide for SPS harmonization with Russia’s WTO obligations. Accordingly, large trading partners such as those in the EU now inform potential exporters of ECU measures while negotiating memoranda of understanding with Russia.<sup>34</sup> The United States reports engagement with both Russian and ECU authorities on SPS issues (U.S. Trade Rep. 2014, p. 75).

Differences in national standards account for some of Russia’s trade frictions in agriculture. While the SPS agreement imposes basic requirements on admissible measures, differences in how WTO members

> 31 Amendment No. 286-FZ (December 2012); Resolution #474 “On Submission of Notifications about the Beginning of Turnover of Alcoholic Products on the Territory of the Russian Federation” (entry into force October 1, 2013); revisions to the “Technical Regulation on Alcohol Product Safety,” and Regulation Order #59 on alcoholic beverages.

> 32 USTR 2014 TBT Report, op.cit., p. 95 **_._**

> 33 European Commission Trade Market Access Database, http://madb.europa.eu/madb/barriers_details.htm?barrier_id=095224&version=5, downloaded June 27, 2014.

> 34 <u>http://ec.europa.eu/food/international/trade/sps_requirements_en.htm.</u>

> RUSSIA’S TRADE POLICY CHALLANGES – THE WORLD BANK GROUP 17