Russia: Non-compliant products. When and how to notify the authorities?

Product manufacturers, manufacturer representatives and importers may use the Methodical Recommendations adopted by the Federal Agency of Technical Regulation and Metrology (RosStandart) in order to determine how and in which cases they have to notify the market surveillance authorities about non-compliant products they placed on the market.

The Recommendations apply to all products subject to Technical Regulations, including electronics, cosmetics, light industry products, food, drinks, toys, etc.

The Recommendations also contain information on how manufacturers and importers are to develop and implement a plan of measures aimed at the prevention of damages resulting from placing non-compliant products on the Russian market.

A manufacturer, its authorized representative or importer (an economic operator) will have to notify the authorities about non-compliant products they have placed on the market if such products have a defect or a fault that leads to any non-compliance with the requirements of any applicable Technical Regulation. In this case, the relevant economic operator is required to notify the Federal Agency on Technical Regulation and Metrology (RosStandart) within ten days from the date on which the operator determined that the uncovered fault or defect will result in non-compliance with the applicable Technical Regulation.

The economic operator who placed non-compliant products on the market is also required to develop and submit to the RosStandard the plan of measures aimed at the prevention of damages that may be caused by such non-compliant products being on the market (the Plan). This Plan must be submitted to RosStandart within ten days from the date of submission of the notification.

The economic operator is permitted to omit submission of the notification and only send to the RosStandart the Plan, provided that the Plan is sent within ten days from the date the operator determined non-compliance with the Technical Regulation.

The Recommendations set out the form for the notification on non-compliant products that is to be sent to RosStandart and provide recommended contents and structure for the Plan.

Download the Decision Tree for the Notification of Market Surveillance Authorities

Law: Order No. 647 of 29 March 2017 on the Adoption of Methodical Recommendations for the Development and Implementation of the Plan of Measures Aimed at Prevention of Damages Resulting from Non-Compliance of Products with the Applicable Technical Regulations