The State Registration Certificate (SRC) Explained
The SRC confirms that products meet the Sanitary Rules and Regulations, and customs cannot be passed without it where the product is on the Unified List. It is issued by the competent national authority, is valid indefinitely, and covers products under three technical regulations plus a further national list.
What is the SRC?
The State Registration Certificate officially confirms that products comply with the Customs Union regulations and are therefore safe. Customs control cannot be passed without it where the product type appears on the Unified List of Goods requiring an SRC. It is issued by the competent national authority of a member state.
Substantively, it confirms that goods have been assessed against the Sanitary Rules and Regulations (SanPiN), under three technical regulations:
- TR CU 007/2011, safety of products for children and teenagers
- TR CU 009/2011, safety of perfume and beauty products
- TR CU 027/2012, safety of certain specialised foods, including dietary medical and dietary preventive nutrition
Under TR CU 007/2011
- Silicone, rubber and latex pacifiers
- Diapers and nappies of non-woven fabric, cotton sticks and pads for children
- Baby bottles, sippy cups, mugs, dishes and other dishware in any material, including disposables, for children under 3
- Toothbrushes including battery-operated ones, where the manufacturer claims them for children under 3
- Swimwear, underwear, babygrows, bonnets and summer headwear for children under 3
- Sleeping suits, underpants, wraparound garments, camisoles, underwear, hosiery and summer headwear for children under 3
These products need both the SRC and the declaration; the two are cumulative.
Under TR CU 009/2011
- Self-tanners and sunscreen creams.
- Products for intimate hygiene and depilation.
- Baby cosmetics and perfume.
- Hair dyes, and products for perming or straightening.
- Chemical peeling products.
- Fluorine-containing mouth care products.
- Peroxide-containing compounds for tooth enamel whitening.
Under TR CU 027/2012
- Nutrition for nursing and pregnant women
- Sports nutrition
- Medical and preventative food products, and children’s dietary nutrition
Beyond the EAEU regulations
A further national list is subject to state registration:
- Materials, equipment, substances and devices used in utility and drinking water supply, wastewater treatment, and swimming pools
- Chemical and petrochemical products for industry, and some household chemicals
- Polymer and synthetic materials for construction, transport, furniture and domestic appliances
- Materials for products in contact with human skin
- Products and goods that are a source of ionizing radiation, and goods containing radioactive substances
- Construction and other raw materials whose radioactive content is regulated by hygienic standards, including industrial waste for recycling, and ferrous and non-ferrous scrap
- Pesticides and agrochemicals
- Materials, products and equipment in contact with food
- Ice-melting chemicals
- Other products subject to temporary sanitary measures introduced by one of the Parties
Who can apply for an SRC?
| Product origin | Applicant |
|---|---|
| Manufactured in a CU member state | The manufacturer |
| Foreign origin | The manufacturer’s representative on CU territory |
The four stages
- Testing and studies, according to the product type.
- Preparation of the document set, including laboratory reports.
- Submission of documents for expertise.
- Issue and execution of the state registration certificate.
The types of study and test are determined by the applicable regulations and standards for the product.
Timelines, and the categories that break them
| Product | Duration |
|---|---|
| Typical | 4 to 6 weeks |
| Nutrient additives | 5 to 6 months |
| Disinfectants | 6 to 8 months |
That spread is the single most important planning fact about the SRC. A project scoped on the four-to-six-week figure will be wrong by half a year for a disinfectant.
Validity
Indefinite. The SRC expires only when supply or manufacture of the products ceases on Customs Union territory.
Which documents are required?
- A sample of the products, in a quantity depending on the type being registered
- Copies of PSRN and TIN
- Information about the manufacturer
- The authorised person’s contract, for imported products
- Product name and description, FEACN codes, technical specifications and formulation
- Recommendations for use, signed or sealed by the manufacturer, where the label cannot carry all the important information
- Label layouts
- Confirmation that an ISO quality management system is used at the enterprise
Sources
- TR CU 007/2011, TR CU 009/2011, TR CU 027/2012, Eurasian Economic Commission
- Competent national authorities, state registration of products and the Unified List of Goods
- SanPiN sanitary rules and norms, as applied by the member states
Frequently asked questions
How long is an SRC valid?
Indefinitely. It expires only when supply or manufacture of the product is terminated on Customs Union territory, unlike a certificate or declaration, which run for a fixed term.
How long does it take to obtain?
Usually four to six weeks. Some categories take far longer: disinfectants can run six to eight months, and nutrient additives five to six months. The category determines which end of that range you are in.
Who can apply?
For products manufactured in a Customs Union member state, the manufacturer applies. For products of foreign origin, the manufacturer's representative on Customs Union territory acts as applicant.
Not sure which of these applies to your product? Send it and we will tell you
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