Today we will talk about labeling that simplifies international trade. Under the spotlight is the EAC mark of conformity on goods: decoding, application rules, dimensions of the EAC label - we will consider all this in detail. For what? So that you know exactly what it looks like, you can spot a fake in time and protect yourself from buying it.
It should be noted that in recent years, cases of import of counterfeit goods into the Russian markets have become more frequent, and therefore the number of open administrative proceedings has increased. This state of affairs is a prerequisite for tightening import-export controls and another compelling reason to be vigilant.
How is it deciphered?
The abbreviation hides the concept of EurAsian Conformity or, in Russian, Eurasian Conformity. By default it is written in Latin, although Cyrillic is also acceptable.
Please note that from July 2021 its presence is mandatory: if before this date the absence was acceptable, then after it the requirements have become stricter, and now an item without this identifier is simply withdrawn from sale.
The place for its placement can be either the item of trade itself, or the container in which it is delivered, and even the accompanying documentation. Although the last option is far from the most visual, so it is better to apply it to things so that it is immediately visible to a potential buyer.
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If an individual is from the Customs Union...
Is the sale of goods by a Russian organization to individuals who are citizens of other CU member states exempt from VAT? In Letter No. 03 07 14/22219 dated June 14, 2013, financiers explain that this is impossible.
When purchasing goods, such an individual will not be able to provide a Russian organization with documents confirming the actual export of goods from the territory of one CU member state (in this case, the Russian Federation) and the import of these goods into the territory of another CU member state. And the submission of such documents is a necessary condition for applying the zero rate.
What should it be applied to?
According to current legislation, it must be present at facilities of the following groups:
- children's and teenagers' things, including toys;
- pyrotechnics;
- Perfumes and cosmetics;
- nutrition (including dietary, preventive and therapeutic) and/or juices made from vegetables and/or fruits;
- equipment (low voltage);
- animal and vegetable oils and fats, as well as their derivatives;
- furniture;
- tobacco products;
- individual protection means.
This is an incomplete list - the list can be continued, which is what the compilers of norms and standards do. Therefore, it is better for foreign trade participants to separately inquire whether this identifier needs to be applied to a particular object of sale or purchase. This approach may seem too thorough, but in the end it will be completely worth it, because it will help you avoid fines and generally problems with the Federal Customs Service and will save time and nerves.
Features of customs control of the EAEU Customs Code
The new code brought pleasant changes and simplified process regulations. Now you can register the goods without personally submitting original documentation, but do this by filling out forms electronically. Also, customs control of the EAEU Customs Code is much faster - up to 4 hours if there are no errors and complete data about the object is submitted. Officials of the authorities practically do not take part in the registration and some types of inspection. Their functions are assigned to automatic systems.
What remains the same, however, are the common challenges faced by stakeholders. Firstly, the legislation has not become easier for people without experience in this field or specialized education. Sometimes requests come with inaccurate, incomplete wording from officials of regulatory (supervisory) authorities or there are not enough documents on successful product certification. And control after the release of goods under the EAEU Labor Code is accompanied by a large number of questions. It is not always possible to quickly figure this out on your own.
Rules for labeling products with the EAC quality mark (EAC)
It is imperative to adhere to them. And, according to them:
- All 3 letters are written in the same font, so that the abbreviation fits organically into the square or oval of the sticker.
- Letters should be strict, with straight lines, without curves or decorations.
- The color must be chosen to contrast with the design of the packaging so that the identifier immediately catches the eye.
- It is important that no other logos, inscriptions or images overlap the abbreviation in question or make it difficult to read.
- It is necessary that the detail is maintained throughout the entire life of the item.
- The minimum height is 5 mm, the maximum is not limited (width too).
If we consider the EAC mark on the marking in detail, the application rules should be supplemented. Please note that it must be included in the accompanying documentation. Otherwise, you may run into a fine for violating consumer rights. Failure to comply with one of the above conditions carries similar sanctions.
This mark is no longer focused only on the domestic, but also on foreign markets: it is already highly rated and is considered an important evidence of the good execution of the object, as well as a characteristic sign of the state’s responsible approach to imports and exports. It is also an important part of the mandatory certification procedure for vehicles and PCT.
When they put the EAC mark on the packaging: requirements for the product for labeling
Products receive this status only when they meet certain conditions. Which one exactly? They are specified in the Technical Regulations (TR) of the EAEU and describe general issues of safety and manufacturing of good quality items.
Confirmation of the proper (high) level of output is carried out through testing. Tests and analyzes are carried out in accredited laboratories, during which competent specialists establish consumer properties and draw conclusions about whether the mark can be applied. If not, the manufacturer will need to eliminate the deficiencies (usually indicated in the reports) and send their products for re-examination.
Who labels goods and where?
The application of the EAC mark on a product is carried out either by its direct manufacturer or by a responsible supplier, but strictly before it goes on sale (circulation). The recipient, if he is not the final consumer, also has the right to do this, but usually it is quite difficult and inconvenient for him to carry out this procedure solely on his own, because it is carried out on expensive equipment, by specialists, who are not always advisable to keep on staff, from an economic point of view.
Where to place the abbreviation
We found out above that all three of its letters must be identical in font, height and length, and also have sharp, rather than rounded, corners. Moreover, it is important that all of them together form an image, on a plain background (dark or light), easily readable and not blocked by anything.
And that’s not all, because it is also important where exactly to put the EAC sign; the requirements for application on the packaging help to take into account the place as follows:
- Any technology (method) is acceptable that ensures proper clarity of the inscription and maintains its visibility throughout the entire period of operation;
- the color must contrast with the surface of the location;
- it is important that the reduction attracts attention so that it can be easily noticed with the naked eye;
- it should be affixed to each unit sold, its container and accompanying documentation;
- the specific placement point is selected in accordance with the CU TR, the scale is at the request of the manufacturer (but with a letter height of at least 5 mm).
Attention, interference - logos, drawings or photos - that would make the abbreviation difficult to read is not permitted. Failure to comply or a clear violation of one of these conditions is a reason for opening an administrative case, sanctions in the form of a fine or withdrawal of the object from circulation (with its confiscation).
How to obtain a certificate of conformity
Labeling of goods with a single EAC product circulation mark is possible only after it has been established that they meet the conditions of the CU TR. This document becomes physical confirmation of the successful completion of all tests. An alternative to it is a declaration - they have the same legal force.
So, to get this paper, you need:
- Contact the issuing center and provide all the specified certificates, certificates, and details.
- Wait for the prototypes to undergo the required tests and laboratory studies, providing all possible assistance to the inspectors.
- Review the results presented in the form of protocols.
- If the commission decides positively, pick up the certificate on the specified date.
Typically, the procedure for obtaining permission to apply a sign of compliance with the technical regulations of the EURASEC Customs Union takes up to 30 working days. The associated costs in the two cases can differ significantly, because they depend on both the cost of registration and the testing. And if the first one is inexpensive - no more than 10,000 rubles - then the second ones often require up to 200-250,000 and take a significant amount of time.
In practice, there are often situations in which it is necessary to receive several declarations at once, in accordance with certain conditions of the CU TR, and organize tests and laboratory studies for each of them, which increases costs to impressive amounts. But this is a mandatory item and cannot be excluded.
How to avoid labeling problems
We have already found out that the customs circulation mark EAC (EAC) must be applied to products before importing goods into Russia, by the manufacturer or supplier. Although, if the seller has economic opportunities, he may not rely on the honesty and responsibility of the importer, but rather take the issue into his own hands. To do this, he should enlist the support of design specialists and take the following actions:
- Agree with the authorized bodies on the sample tag that he is going to use, as well as its location.
- Send the abbreviation design to the other party for approval.
- Think over and include in the supply contract the obligations for applying the letters (in particular, who exactly should do this, and what sanctions are provided for failure to comply with the conditions).
In cases where the sign of the EAC customs union is incorrectly placed on the label (the letter sizes are different, it is difficult to read, etc.), or when it is completely absent, the seller can independently correct the situation, that is, make the correct mark. True, the right to carry out this procedure still needs to be obtained from the regulatory authority, which will take several working days, or even a week, and no one has canceled the associated costs.
Therefore, it is better to make sure before delivery that the abbreviation meets all the conditions - ask the other party for a photo or video report. This approach will help avoid not only wasted time and fines, but also misunderstandings, conflicts, and litigation between the parties to the transaction.
Penalty for lack of EAC certification mark
If the regulations require the mandatory application of this mark, but in fact it is not there, such an offense entails one of the following sanctions:
- initiation of an administrative case with an investigation;
- monetary payment (depending on the case) - up to 300,000 rubles for ignoring the current conditions of the CU TR or up to 10,000,000 - for violation of consumer rights, or up to 30,000,000 - for incorrect implementation procedures.
The amounts are more than serious, and enforcement proceedings slow down foreign economic activity for up to 60 days. During this period, you will have to pay additionally for the storage of imported objects at the rate of 200 rubles/day per 1 piece of cargo.
It turns out that one mark of conformity of the Eurasian Economic Union not applied to a label or packaging leads to large financial losses? Yes, although these expenses can be easily avoided - you just need to be responsible about the issue and control how it is marked.
It should also be remembered that fines are issued not only in the absence of a label, but also when it does not meet the conditions of the CU TR. Therefore, it is so important to maintain a single font, take care of the contrast with the surface, make the image clear, noticeable and readable, and make sure that nothing overlaps it. A little practice, and this will not be a problem, but we are ready to suggest you several design and layout options right now.
Types of EAC icons on labels and stickers
The ideal case is a mark on a tag: it immediately catches the eye, but at the same time you don’t have to, for example, tear it off the side of a cardboard box. But it is not always possible to place it in this way, especially if products are imported that were not manufactured in the country from the Customs Union.
It is precisely for such situations that other media are provided, which:
- can provide proper contrast between the main color and background, as well as image clarity;
- are easily attached to the container and do not get lost during transportation;
- they resist abrasion quite effectively and are, in principle, durable;
- are produced in various diameters, which means they help to implement the required dimensions of the EAC mark marking (10, 15, 20 mm);
- are manufactured in long rolls, designed for 1-10 thousand tags;
- They are inexpensive to produce.
Stickers have all these features, which is why we want to draw your attention to their most successful options.
Made from plain paper, white background, black letters, D10 mm
A true classic: compact, with a familiar design, cheap to manufacture, but at the same time capable of serving for a sufficient period of time.
From “golden” paper, D10 mm
Compared to the previous ones, they look more rich and representative, thanks to the spectacular shine, but at the same time remain well readable.
Made from “silver” paper, D10 mm
Another visually attractive, but clear look, the letters of which do not blend into the background, and the size of the EAC icon remains compact enough so that it looks organic even on small-sized products.
From white film
Also a classic with a self-adhesive base, most often used in cases where you need to quickly put marks on a large number of items. It is somewhat more expensive to manufacture than the already presented options, but it is more difficult to accidentally damage.
Made from transparent film
On such stickers, the letters are as visible as possible, but only when placed on a suitable surface. Since the abbreviation is made in a dark color, it means that the plane should be light.
Made of paper, white background, black letters, D15 mm
Here the diameter has already been expanded, which only contributes to clarity (although it results in an increase in material consumption), but otherwise it’s still the same classic.
Made of paper, white background, black letters, D20 mm
It differs from the previous type in size. Relevant for large-sized goods imported into the territory of the countries of the Customs Union: the EAC designation is not lost even on large boxes, successfully adjacent to other inscriptions - it immediately catches the eye, is perfectly readable, that is, it meets the basic conditions of the CU TR.
Made of paper, black background, white letters, D20 mm
An option made in contrast to the one just discussed, and suitable for light surfaces. It has been proven that such a sticker attracts attention, and it is very difficult to shade it with something - as long as it does not overlap with some color images.
All of them are usually produced in rolls in quantities of 1, 5 and 10 thousand pieces - for different needs and budgets. The costs of their purchase are negligible on the scale of any serious manufacturing enterprise, supplier and large seller.
We examined in detail what the EAC marking on products means and what goods it applies to; we also examined the requirements of the Technical Regulations for it - so that you understand how important it is to apply it correctly.
Now you can safely move on to creating such stickers yourself, and you will find programs for performing such work in the Cleverence catalog. Number of impressions: 14679
Commission agreement.
What if a Russian organization sells goods to buyers from another CU member state through a commission agent who is a resident of that other state? Confirmation of the right to apply the zero VAT rate occurs practically in the usual manner typical for the export of goods from the Russian Federation to a member state of the Customs Union.
According to Art. 1 and 2 of the Agreement between the Government of the Russian Federation, the Government of the Republic of Belarus and the Government of the Republic of Kazakhstan dated January 25, 2008 “On the principles of levying indirect taxes on the export and import of goods, performance of work, provision of services in the Customs Union” (hereinafter referred to as the Agreement), the export of goods is understood to be documented confirmed export of goods sold by taxpayers of member states of the Customs Union from the territory of one member state of the Customs Union to the territory of another member state of the Customs Union.
Documentary confirmation consists of submitting documents as specified in paragraph 2 of Art. 1 of the Protocol on goods to a list supplemented by agreements between a foreign commission agent and foreign buyers (Letter of the Ministry of Finance of Russia dated May 29, 2012 No. 03 07 15/54 [5]). Without such agreements, it is difficult to confirm the fact of export of goods from the Russian Federation to another state.
