Russia’s use of pre-shipment inspections and other formalities is high by international standards, as is its use of price-control measures. As Figure 3 shows, the frequency ratio for pre-shipment inspections and other formalities<sup>24</sup> (UNCTAD category C) exceeds 90 percent for most product categories, as does the frequency of price-control measures, such as additional taxes and charges (UNCTAD category F). These measures are relatively uncommon for other countries—frequency ratios for pre-shipment inspections and other technical measures are typically under 20 percent in most countries, while frequency ratios for price control measures are typically under 10 percent.<sup>25</sup> The data may understate the use of other formalities— requirements to pass through specific ports for customs are reported to be numerous and burdensome<sup>26</sup> but do not appear in the UNCTAD data.

SPS measures in Russia and the ECU extend well beyond agriculture. It is customary for most countries to have SPS measures for the majority of agricultural imports (HS 01-24), but Russia also has SPS measures for many chemical products; plastic and rubber products; hides, skins, and leather; wood and wood products; and textiles (Figure 3), for which SPS measures are rare internationally—the EU profile is presented as a comparator. The appearance of SPS measures in some of these unusual categories is reflected elsewhere in the ECU, in particular Kazakhstan.

While there are some cases in which SPS measures may be appropriate in non-food sectors (e.g. for pests that may travel in wood products), it is not clear why Russian SPS measures have such a broad coverage. Since many of these measures are for products not intended for human consumption, and not usually subject to quarantine risk, there is the potential that some of these measures could lead to frictions with trading partners and may be vulnerable to WTO challenge.

The profile of Russia’s technical barriers to trade is similar to that of the EU. As figure 4 shows, the frequency of Russia’s TBT measures and the EU’s are similar, reflecting a complex and elaborate regulatory system. TBT barriers are less likely to be seen in ECU member Kazakhstan as of 2012, although operation of the ECU should in theory cause these to be harmonized over time.

# **NTMs and Russia’s trading partners**

When NTMs weigh heavily on trade, traders and trading partners are likely to express their concerns. Exporters having difficulty doing business in Russia are likely to register complaints with their own governments, which in some cases will elevate these to public attention. Such concerns do not always mean that an NTM is having a significant economic effect, or that it creates a problem for the WTO or another legal arrangement. Nonetheless, the concerns of traders, whether or not shared by their governments, provide a valuable supplement to legal descriptions of NTMs in terms of where there might be an economic impact. Moreover, for every authentic case of an exporter having difficulty selling to Russia, there is likely to be a Russian importer having difficulty in buying whose activities and customers are similarly disadvantaged.

> 24 These include direct consignment requirements, requirements to pass through specified port of customs, import-monitoring and surveillance measures, and other automatic licensing measures.

> 25 Breaux et al (2014), op.cit.

> 26 See below under Customs.

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