Certification of Food Products in Russia: A Comprehensive Overview

The certificate EAC and declaration EAC of conformity of food products in the Russian Federation is a legally mandated procedure designed to ensure the safety and quality of goods entering the market. This process primarily takes the form of mandatory declaration, conducted by authorized and accredited certification bodies. These bodies operate in strict adherence to the provisions outlined in the technical regulations of the Customs Union, now known as the Eurasian Economic Union (EAEU).

Mandatory Documentation for Food Products:

According to the current regulatory framework governing technical standards within the Russian Federation, the issuance of two primary documents is obligatory for all food products intended for circulation:

1. Laboratory Test Report: This report documents the results of laboratory analyses conducted on product samples, verifying their compliance with established safety and quality parameters.
2. Declaration of Conformity (EAC): This declaration, bearing the EAC (Eurasian Conformity) mark, is a statement by the manufacturer or supplier affirming that their food products meet the requirements stipulated in the relevant EAEU technical regulations.

Voluntary Certification 

While mandatory declaration is the primary form of conformity assessment, manufacturers retain the option to pursue voluntary certification of their food products within the national Russian GOST R system. This voluntary certification can serve as an additional indicator of quality and can enhance consumer trust. However, it is crucial to understand that voluntary GOST R certificates and mandatory declarations of conformity are distinct and not interchangeable.

Prerequisites for Voluntary Certification:

Enterprises considering voluntary certification must first ensure that they have obtained the mandatory laboratory test report and declaration of conformity. These mandatory documents are considered foundational and hold primary legal significance.

Costs and Timelines Associated with Conformity Assessment 

The financial and temporal aspects of food product conformity assessment are important considerations for businesses:

• Cost of Declaration: The cost for registering a declaration of conformity is approximately 450 USD.
• Cost of Tests: Laboratory testing expenses can vary, starting from around 300 USD, depending on the product type and the scope of analysis required.
• Registration Period: The typical registration process for a declaration of conformity takes approximately 2 weeks, following the successful completion of laboratory tests.

Key Technical Regulations Governing Food Safety 

Several crucial technical regulations of the Customs Union/Eurasian Economic Union define the safety and quality standards for various categories of food products:

• “On the safety of food products” (TR CU 021/2011): This overarching regulation establishes general safety requirements for all food products.
• “Food products in terms of their labeling” (TR CU 022/2011): This regulation specifies the mandatory information that must be included on food product labels.
• “On the safety of milk and dairy products” (TR CU 033/2013): This regulation sets safety and quality standards for milk and products derived from milk.
• “On the safety of meat and meat products” (TR CU 034/2013): This regulation outlines the safety and quality requirements for meat and meat-based products.
• “On oil and fat products” (TR CU 024/2011): This regulation governs the safety and quality standards for vegetable oils and fats.
• “On juice products from fruits and vegetables” (TR CU 023/2011): This regulation establishes requirements for fruit and vegetable juices and nectars.
• “Safety requirements for food additives, flavorings, and technological aids” (TR CU 029/2012): This regulation defines the safety standards for substances added to food.
• “On the safety of fish and fish products” (TR EAEU 040/2016): This regulation sets the safety and quality standards for fish and seafood products.

Procedure for Declaring Food Products:

The process of declaring the conformity of food products typically involves the following steps:

1. Application Submission: An application or request, often submitted electronically, containing a list of the products for which declaration is sought, is submitted to a certification body to determine the applicable costs.
2. Sample and Document Provision: The applicant provides product samples for laboratory testing, along with necessary documentation pertaining to their company.
3. Laboratory Testing: The submitted samples undergo a prescribed cycle of tests in an accredited laboratory. Following the tests, the laboratory issues a conclusion or test report. A positive test report indicates that the samples comply with the relevant standards.
4. Declaration Registration: If the test results are positive, an electronic declaration of conformity is registered. Information about the registered declaration is automatically entered into a unified electronic register maintained by the relevant authorities.
5. Issuance of Documentation: The applicant receives the original laboratory test protocol, along with the original contract for services and a certificate of completion from the certification body. The entire registration procedure typically takes around ten working days.

Shift from Production Analysis to Finished Product Testing:

Historically, under the mandatory certification system that preceded the current declaration system, an analysis of the production process was a standard component of conformity assessment for food products. However, the current declaration system focuses primarily on the safety and quality of the finished product. As such, routine analysis of production conditions is no longer a mandatory requirement. Only the final product undergoes testing to verify its compliance with established standards. The long-term implications of this shift, whether positive or negative for overall food safety, remain a subject of ongoing observation.

Key Information Included in a Declaration of Conformity:

The declaration of conformity for food products contains essential information about the product and its manufacturer, including:

• The full name of the manufacturer, their legal address, and the address of their business operations (production facilities).
• The name and brand of the specific food product being declared.
• The number of the regulatory document (e.g., GOST, TU) according to which the product is manufactured.
• The protocol number and date of registration of the laboratory test report that supports the declaration.
• The period of validity of the declaration of conformity.

Scope of Mandatory Declaration for Food Products:

In Russia, most food products are subject to mandatory declaration of conformity rather than mandatory certification. This means that for the majority of food items, a declaration of conformity is the required form of conformity assessment. 

Exceptions to Mandatory Declaration EAC:

There are specific categories of unprocessed livestock products that are exempt from the mandatory declaration requirement. These include:

• Live and frozen fish and seafood.
• Meat, including carcasses and half carcasses.
• Eggs.
• Unprocessed natural honey.
• Raw milk.

For these specific unprocessed animal products, a veterinary certificate issued through the Mercury system is the required form of documentation to ensure their safety and traceability. All other categories of food products generally fall under the mandatory declaration of conformity.

Specific Regulations for Baby and Specialized Foods:

Baby food and specialized dietary foods are subject to a more stringent regulatory process than general food products. These categories require mandatory state registration with Rospotrebnadzor, the Federal Service for Surveillance on Consumer Rights Protection and Human Wellbeing. Manufacturers of these products must first obtain state registration certificates before they can be legally marketed.

Conformity Assessment for Catering Services:

Catering services, such as those provided by cafes, restaurants, and canteens that prepare and sell ready-made meals on their premises, are not subject to mandatory certification or declaration of conformity. The regulatory focus for these establishments is typically on adherence to sanitary and hygiene standards.

Verifying the Authenticity of a Declaration of Conformity: 

To ensure the legitimacy of a declaration of conformity, the Russian Federal Accreditation Service (Rosaccreditation) maintains an electronic register that contains information about all registered declarations and certificates of conformity. This online resource is publicly accessible, allowing any user to verify the authenticity of these documents. Verification can be performed by inputting details about the manufacturer’s organization. It is generally sufficient to enter the name of the organization and initiate a search. The system will then display any relevant declarations or certificates associated with that company.

Required Documentation for the Declaration Process: 

To initiate the declaration of conformity process, applicants typically need to provide the following documents:

• Copies of the Taxpayer Identification Number (TIN) and the Main State Registration Number (OGRN) certificates of the applicant organization, duly certified with the organization’s official seal. 
• A comprehensive company details card containing essential information about the applicant.
• Technical Specifications (TU) if the product is not manufactured according to an existing national GOST standard.
• A copy of the lease agreement for the production premises, certified with the company’s seal.
• A formal application for the declaration of conformity.
• An electronic digital signature (EDS) is typically required for submitting the declaration electronically.
• Supporting documentation as specified by the relevant technical regulations.

Techsert Groups LLC assists and can produce and/or provide most of those documents on request.