Traced goods: From October 1, 2026, the rules for importing goods from the EAEU under the Special Trade Agreement will change.
The Russian government has amended the national product traceability system. These amendments affect organizations and individual entrepreneurs who import traceable goods from Eurasian Economic Union (EAEU) member states and use the Confirmation of Expected Delivery system.
The changes will come into force on October 1, 2026, and are aimed at further digitalizing control over the circulation of goods, as well as reducing the number of duplicate procedures in business interactions with tax authorities.
Although these innovations are technical in nature, companies involved in foreign economic activity should assess their impact on internal accounting and document management processes in advance.
What is a product traceability system?
The national product traceability system has been in place in Russia for several years and is designed to monitor the movement of certain product categories from their import into the country to final sale.
The main objective of the system is to ensure transparency of trade flows, reduce the risk of tax evasion schemes, and prevent illegal trade in goods.
Participants in the marketplace are required to reflect information about traceable goods in documents and reports, and to submit relevant information to tax authorities.
The system is of particular importance for importers, since it is at the import stage that the registration number of a batch of goods is generated, which is subsequently used at all stages of further circulation.
What changes will come into force from October 2026?
The main innovation concerns the procedure for processing documents when importing traceable goods from EAEU countries within the framework of the confirmation of pending delivery of goods system.
Until now, participants in the market were required to send a notification to the tax authority about the import of goods in order to obtain a batch registration number.
From October 1, 2026, a different mechanism will apply to transactions carried out through Confirmation of Expected Delivery system.
If the importer submits a document on the upcoming delivery of goods to the tax authority, a separate import notification will no longer need to be submitted.
In fact, the upcoming delivery of goods will become the basis for further processing of information by the tax authority without the need to duplicate information in a separate notification.
Thus, the legislator seeks to reduce the administrative burden on businesses and eliminate situations where the same information is submitted to government agencies multiple times.
How will the batch registration number be assigned?
Along with the abolition of the obligation to submit a separate notification, the procedure for assigning a registration number to a batch of traceable goods is changing.
Upon receipt of a document regarding the upcoming delivery of goods, the tax authority will independently generate a batch registration number and send it to the participant in the transaction via telecommunications channels.
The Federal Tax Service must do this no later than the next calendar day after receiving the additional payment order.
In practice, this will speed up document flow and reduce the number of manual operations on the part of the importer.
For businesses, this means a faster transition from the delivery registration stage to the subsequent reflection of transactions in accounting systems.
When will corrective notices need to be filed?
Despite a certain simplification of the procedure, the new rules simultaneously strengthen the requirements for the relevance of the information contained in the traceability system.
If, after submitting the upcoming delivery of goods, it becomes clear that the information about the delivery has changed, the importer is obliged to notify the tax authority about this.
A correction notice will need to be sent in the event of a change:
- quantity of goods;
- cost of goods;
- units of measurement;
- other information affecting the accounting of a batch of traceable goods.
The deadline for submitting such notification will be quite short – no later than the next business day after the error is discovered or discrepancies are identified.
This means that companies need to ensure efficient interaction between departments responsible for procurement, logistics, customs support and accounting.
If the goods were not actually imported
Another important innovation concerns situations where delivery, for one reason or another, does not take place.
According to the new rules, a correction notice will need to be sent not only when delivery details change, but also when goods were not actually imported into the Russian Federation or there are no grounds for accepting them for accounting.
For example, this situation may arise:
- in case of cancellation of delivery after registration of documents;
- in case of refusal of goods;
- upon termination of a foreign trade contract;
- in case of a significant change in the terms of the transaction;
- when circumstances are identified that prevent the acceptance of goods for accounting.
In such cases, the importer is obliged to notify the tax authority no later than the next working day after the relevant circumstances are identified.
What does this mean for foreign trade participants?
At first glance, the changes may seem purely technical. However, in practice, they affect key business processes for companies importing goods from EAEU countries.
On the one hand, the procedure becomes simpler due to the elimination of additional import notification when using the Confirmation of Expected Delivery system mechanism.
On the other hand, the importance of the quality of primary data and the speed of their adjustment increases significantly.
While previously individual inaccuracies could be identified and corrected later, businesses will now need to monitor changes in supply parameters in near real time and promptly submit corrective information to tax authorities.
Particular attention should be paid to data synchronization between:
- purchasing departments;
- logistics units;
- accounting;
- foreign trade specialists;
- electronic document management operators.
Any discrepancies between actual delivery information and the information contained in the traceability system may result in additional inquiries from tax authorities and the need to make adjustments.
Recommendations for business
Before the changes come into effect, companies are advised to audit their current processes for handling traceable goods and check the readiness of their internal procedures for the new requirements.
In particular, the following issues are worth paying attention to:
- Are Confirmation of Expected Delivery system’s mechanisms used when importing goods from the EAEU?
- How is control of information reflected in the upcoming delivery of goods carried out?
- who is responsible for identifying errors and discrepancies;
- how quickly information is transferred between company divisions;
- Do accounting systems allow for the timely generation of correction notifications?
Preparing in advance will help avoid problems once changes come into effect and reduce the risk of errors when working with the traceability system.
From October 1, 2026, new rules for interaction with tax authorities will come into effect for participants in the circulation of traceable goods imported from EAEU countries under the Confirmation of Expected Delivery system.
The main change will be the elimination of the requirement to submit a separate import notification when using a document confirming the upcoming delivery of goods. At the same time, the role of corrective notifications will increase, requiring them to be submitted as soon as possible in the event of any changes to delivery information or cancellation of the import of goods.
Companies engaged in foreign economic activity can now assess the impact of these innovations on their business processes and, if necessary, adjust their internal regulations for handling traceable goods.