An EAC refusal letter is an information document, not a permit document. It records a product-specific conclusion that mandatory certification or declaration does not apply after the goods, intended use and relevant regulatory scope have been reviewed.
An EAC refusal letter does not replace an EAC certificate or an EAC declaration. It cannot remove a conformity assessment obligation where an EAEU or Russian requirement covers the product. Before preparing a refusal letter for Russia or the EAEU, the product must be identified and compared with the applicable technical regulations, mandatory product lists and other relevant requirements.
The review should cover the manufacturer, model, function, materials, power source, operating principle, intended users and destination market, together with technical documents that distinguish the product from similar goods. Where necessary, the reviewer also considers product classification information, current mandatory national lists and the product’s actual configuration. Reestr Garant provides a product scope review and explains whether the appropriate route is an information letter, an EAC declaration or an EAC certificate.
What an EAC refusal letter means
“Refusal letter” is a commercial term for an informational conclusion about identified goods and the legal basis reviewed. The law does not establish one universal form for this document. It is not an EAC certificate exemption, is not entered in the unified register of EAC certificates and declarations, and does not grant a general right to sell any product in Russia or the EAEU.
The document should relate to the goods that will actually be imported, sold or presented to a marketplace. A conclusion about one model or configuration should not be expanded automatically to a whole product family when other models have different functions, materials, power sources or intended uses.
Which outcome is appropriate depends on the product scope:
- If the identified product is outside the applicable mandatory conformity assessment scope, an information refusal letter may be appropriate.
- If the product falls within a mandatory declaration scope, the eligible applicant must complete and register an EAC declaration under the applicable rules.
- If the product falls within a mandatory certification scope, an accredited certification body must perform the required certification actions and issue an EAC certificate if conformity is established.
- If the product is outside one technical regulation but may be covered by another, the review must continue before a conclusion is issued.
A refusal letter does not guarantee customs clearance, marketplace acceptance or unrestricted sales. A customs representative, marketplace or business partner may request particular evidence under its own procedure, but that commercial request does not determine whether mandatory conformity assessment applies.
Refusal letter, EAC certificate and EAC declaration
These documents have different purposes and assign different actions to the parties involved. A refusal letter communicates a non-applicability conclusion, while an EAC certificate or EAC declaration records conformity under an applicable EAEU procedure.
| Document | Purpose | Who acts | When it may apply |
|---|---|---|---|
| Information refusal letter | Communicates that mandatory certification or declaration does not apply to identified goods | A compliance service provider or other issuer prepares the information document after reviewing the product and legal scope | When the product is outside the applicable mandatory conformity assessment requirements |
| EAC certificate of conformity | Confirms conformity through a certification procedure | An accredited certification body performs the certification actions; the applicant meets the applicable applicant requirements | When a technical regulation places the product within a mandatory certification scope |
| EAC declaration of conformity | Records the eligible applicant’s statement of conformity, supported by required evidence | The eligible applicant signs and registers the declaration under the applicable rules; testing and other evidence may be required | When a technical regulation places the product within a mandatory declaration scope |
An EAC certificate is issued through certification, whereas an EAC declaration is signed and registered by the eligible applicant under the governing conformity assessment rules. A foreign manufacturer may need an EAEU-resident applicant or authorized representative for one of these procedures, depending on the applicable regulation and the applicant requirements attached to the selected route.
EAEU technical regulations may establish different assessment schemes. The applicable scheme comes from the technical regulation governing the product, not from a general list selected for convenience.
How the product scope is checked
Product identification
A commercial name alone may not establish the regulatory status of goods. Reestr Garant reviews the product name, manufacturer and models together with the intended use, main functions, construction, materials, power source, operating principle, packaging, accessories and user category where relevant.
The customer should provide product data sheets, manuals, drawings, photographs, model or article numbers, packaging photographs, composition information, electrical specifications and any existing test reports, certificates or declarations. The required evidence depends on the product, and a particular document is not automatically sufficient for every scope review.
Regulatory comparison
The reviewer compares the identified product with the applicable EAEU and TR CU technical regulations, their annexes, mandatory product lists and conformity assessment provisions. The unified product list may also be relevant. Official lists and regulatory provisions determine whether the product is within a mandatory certification or declaration route.
The EEC directory of technical regulations and the official Russian publication of Government Resolution No. 2425 are reference sources for the regulatory review where their subject matter is relevant. A GOST standard is not treated as mandatory merely because it describes a technically suitable method. Its legal relevance must come from the applicable regulatory framework or from its use as supporting technical evidence under the applicable procedure.
A negative result under one regulation is not a general exemption from every conformity assessment requirement. A product may be outside one technical regulation and still fall under another regulation, list or national requirement. The review therefore considers the product’s characteristics and intended use across the rules that could cover them.
Applicant and market route
The foreign manufacturer, importer, distributor, EAEU-resident applicant, certification body, testing laboratory and party requesting the information letter may have different roles. The responsible party depends on the applicable technical regulation and conformity assessment scheme, so one participant should not be described as performing every action.
A refusal letter does not create or replace the applicant required for an EAC certification or declaration procedure. If the product is regulated, the eligible applicant must be identified before the relevant conformity assessment begins.
Evidence and checks before issuing the letter
The conclusion is only as specific as the evidence supporting product identification. Technical documentation should show what the product is, how it operates and which models or configurations are covered. The reviewer may request clarification when photographs, manuals, model numbers or specifications do not establish the relevant characteristics.
Regulatory evidence should state which technical regulations, annexes, lists or other provisions were checked and why the product does or does not fall within their scope. A useful document explains the basis for the conclusion instead of simply asserting that certification is unnecessary.
Existing EAC documents and information about certification bodies, laboratories or other conformity participants should be checked against official unified registers or Rosakkreditatsiya information where applicable. This check helps distinguish a current conformity document from an old, inconsistent or unreliable reference.
Check the issuing organization before relying on an old document. JSC VNIIS, the All-Russian Research Institute of Certification, was removed from the Unified State Register of Legal Entities on November 10, 2022, following a registration authority decision dated July 25, 2022. The organization ceased to exist as a legal entity. A current document issued in its name requires particular scrutiny, although the existence of an old reference does not by itself establish that every historical document is invalid.
What the information letter should contain
There is no universal legally prescribed form for an EAC refusal letter. Its usefulness depends on traceability and consistency with the goods, evidence and legal review. The document should identify, as applicable:
- the issuer and issue date;
- the manufacturer, applicant or customer;
- the exact product name and model, article or series information;
- the product characteristics relevant to the scope review;
- the intended use where it affects the assessment;
- the technical regulations, annexes and lists reviewed;
- the conclusion that mandatory certification or declaration does not apply;
- the basis for that conclusion; and
- the signature and contact details of the issuing party.
The wording should match invoices, packing lists, technical files and marketplace records. An overly broad description can create questions when the shipment includes models or configurations that were not reviewed. The letter is not registered in the unified register of EAC certificates and declarations, and no universal validity period, registration number, processing time or state fee should be assumed.
When an EAC certificate or declaration is required
If the product appears in a mandatory certification scope, certification is the correct route and a refusal letter is not an alternative. If the product appears in a mandatory declaration scope, the eligible applicant must complete the applicable declaration procedure and register the declaration under the governing rules.
Test reports, technical files and manufacturer information may support an EAC declaration or certification procedure, but they are not automatically an EAC certificate or declaration. EAC marking also depends on the applicable EAEU rules and product status; not every product is subject to the same marking requirement.
CE marking does not automatically fulfill EAEU requirements. CE documents may be reviewed as technical information, but they do not become an EAC certificate or EAC declaration and do not remove the need to follow the applicable EAEU conformity assessment procedure.
Service scope and working process
Reestr Garant does not act as a regulator or claim that every product qualifies for a refusal letter. The service identifies the appropriate route and prepares an information document only when the reviewed facts support a non-applicability conclusion.
| Stage | Action and responsible party | Output |
|---|---|---|
| 1. Product intake | The manufacturer, importer or distributor provides product identity, models, function, specifications and available documents | Product information package |
| 2. Scope identification | The compliance specialist checks potentially applicable technical regulations and product lists | Scope assessment |
| 3. Regulatory comparison | The product characteristics are compared with mandatory certification and declaration provisions | Reasoned regulatory conclusion |
| 4. Route selection | The parties determine whether the route is an information letter, EAC declaration or EAC certification | Recommended conformity route |
| 5. Evidence review | The customer and compliance specialist check technical documents and existing test evidence | Evidence gap list or confirmed file |
| 6. Document preparation | The service provider prepares an information letter only when the review supports non-applicability | Draft or final information letter |
| 7. Final verification | The customer and service provider check the product description, legal basis and issuer details | Document package for its intended use |
The table describes the service sequence, not a guaranteed outcome or a universal legal procedure. If certification or declaration is required, the applicable technical regulation determines the precise evidence, applicant role, assessment scheme and actions of the certification body or other participants.
Cost factors and practical questions
The cost of a product scope review depends on the quality of the technical information, the number of models or configurations, product complexity, the number of potentially relevant regulations and the need to compare several lists. Translation, missing specifications and review of existing documents may also affect the work required.
A clearly described product with one configuration may require less analysis than goods with electrical functions, accessories, several versions or different intended uses. Several unrelated products should be assessed product by product rather than combined into one generic conclusion.
If an EAC certificate or declaration is required, the cost factors change and may include testing, technical documentation, the applicable scheme, an EAEU-resident applicant, a certification body or a laboratory. No fee, processing time or validity period should be stated without confirmation for the specific product and current procedure.
“I only need a letter for customs.”
A customs broker or logistics provider may request a refusal letter, but that request does not determine the product’s legal status. The product must still be checked against the applicable technical regulations and lists. If an EAC certificate or declaration is required, the letter is not an alternative.
“The manufacturer already has a CE certificate.”
CE documentation relates to the applicable European framework. EAEU conformity assessment follows EAEU and TR CU technical regulations, applicant rules and applicable EAC marking requirements. CE documents may support technical review, but they do not automatically satisfy EAEU requirements.
“Can one letter cover our catalog?”
Only a documented review can determine whether several models share the characteristics and regulatory scope needed for one conclusion. A broad catalog should not be included automatically when models have different functions, configurations or intended uses.
FAQ about an EAC refusal letter Russia
What is an EAC refusal letter in Russia?
It is an information document stating that a specific product does not require mandatory certification or declaration after identification and regulatory review. It is not an EAC certificate, EAC declaration or general authorization to sell goods.
Is the letter registered in the Rosakkreditatsiya unified register?
No. The refusal letter is not a mandatory EAC conformity document registered in the unified register of EAC certificates and declarations. EAC certificates and declarations follow their own conformity assessment and registration procedures.
Can it replace an EAC certificate or declaration?
No. A product within a mandatory certification scope must follow certification, and a product within a mandatory declaration scope must follow the declaration procedure. An information letter is appropriate only when the review supports non-applicability.
Does a foreign manufacturer need an EAEU-resident applicant?
The requirement depends on the EAC certification or declaration procedure and the applicable applicant rules. An EAEU-resident applicant may be required for a regulated conformity assessment, while a refusal letter does not replace that role.
How can an existing letter be checked?
Compare its product description, models, intended use, legal basis, issue date and issuing organization with the goods and current regulatory scope. Where it refers to an EAC certificate, declaration, laboratory or certification body, check the relevant official register information or Rosakkreditatsiya information where applicable.
Request a product scope review
Send the product name, model information, intended use and available technical documents for an initial market-entry check. Reestr Garant will explain whether the appropriate route is an information letter, EAC declaration or EAC certificate for Russia and the EAEU.
Request an initial market-entry check or see published pricing examples.