The Exemption Letter (in Russian ИНФОРМАЦИОННОЕ ПИСЬМО, also called the VNIIS Exemption Letter) is a certificate that can be issued when the product to be exported to Russia, or any other country in the Eurasian Economic Union, does not fall within the mandatory scope of either EAC or GOST certificates.
This kind of “legal vacuum” does not, in itself, imply free movement for the product. What it does is to require, on the one hand, the creation of a document to allow customs clearance and, on the other hand, a certificate of quality, once the product has entered the Russian market. These two requirements are applied in two types of Exemption Letter that have little to do with each other, as the only thing they have in common is that neither GOST nor EAC standards can be applied to the certified product.
Before to examine the two typologies in detail, it’s important to point out that the Exemption Letter does not allow EAC Marking in any case.
1. Customs Exemption Letter
This is an essential document for customs clearance, as it certifies that the product is not subject to any mandatory EAC or GOST certification. As we have already mentioned, it is not possible to carry out the customs clearance through a voluntary GOST Certificate. However, the Exemption Letter (Отказное письмо in Russian), addressed to the Customs Service, is necessary.
What follows is a short list of the most common products excluded from EAC regulation, with its tariff code:
- PET pipes (3917)
- Systems for PVC cabling (3925, Fire Certificate may be needed)
- Plastic conveyor belts (3926)
- Frames (4414)
- Tiles (6907)
- Ceramic vessels or objects (6913)
- Mirrors (7009)
- Crystal glasses (7013)
- Faucer (specific codes of 8481, only intended for domestic use)
- Prefabricated buildings (9406 Fire Certificate may be needed)
2. Commercial Exemption Letter
After completing the customs procedures, the exporting company may need a second Exemption Letter, this time for commercial purposes. This document certifies both the quality of the product, and the fact that GOST regulations cannot be applied to it.
After the introduction of the Eurasec norms, the companies that request the Commercial Exemption Letter ask for a special note that certifies that the product is also outside the scope of the EAC norms. This element of added legal security allows them to move in a more comfortable framework within the country in which they apply for the document. This is even the case if, from a legal point of view, it is not particularly valid in another country belonging to the Customs Union (for example Russia may not recognize a Trade Exemption Letter issued in Kazakhstan).
