More and more devices are interconnected through wireless networks. Data transmission protocols allow us to carry out everyday operations: access a parking, make a purchase, connect a smartphone to a car, etc. The irruption of the so-called IoT (Internet of Things) in our lives will further deepen this trend.
For this reason, every day more (and more heterogeneous) international manufacturers have to go through a certification procedure when they want to export to Russia (and to other countries of the Eurasian Union) equipments that, apart from their primary function, transmit and receive a constant stream of data in order to function.
If in the past by “radio frequency equipment” we meant only radios, televisions or even mobile phones, today any device connected (or connectable) to Bluetooth and Wifi falls into this category.
Here we are going to talk about the specific certification that applies to this type of product. It is worth noting that the EAC Marking is anyway mandatory: it will almost always be necessary to obtain an EAC Declaration of Conformity, based on the CUTR 020/2011 (EMC) regulation and often also on the CUTR 004/2011 (Low Voltage). Less frequently, it may be necessary to obtain an EAC Certificate of Conformity, based on the same regulations.
Products subject to FSB Notification
The FSB Notification is a mandatory document, required for customs clearance, which is issued by the public body FSB (Federal Security Service, in Russian Федеральная служба безопасности Российской Федерации).
This is not a notification that applies in general to all radio frequency equipment, but is linked to the cryptography tools that these types of devices usually incorporate. Due to APIs and encryption algorithms, manufacturers of mobiles, computers, tables, mice, servers, etc. have to request this document.
Any device on this (non-exhaustive) list, as long as it includes cryptographic functions, is subject to FSB Notification:
- Printers, copiers, faxes and their electronic modules
- Pocket devices and computers
- Desktop computers, laptops and their parts
- Electronic modules and portable machine parts
- Telecommunication equipments and its parts
- Devices for software encryption
- Broadcasting or television equipment and parts thereof
- Radio navigation receivers, remote control equipment and parts
- Internet access equipment and television receivers
- Integrated electronic circuits, memory devices
- Other electrical machines and appliances with cryptographic functions
FSB Notification or Exemption: the same procedure
The FSB may issue a Letter of Exemption instead of the Notification.
This is the case of the equipments in the list above that do not include cryptographic means (which must be duly documented) and the equipments whose HS code is not subject to the FSB Notification, even if they include cryptographic means or radio frequency communication protocols. The list of HS codes subject to FSB Notification is limited: any code not included in this list is exempt from Notification, regardless of the algorithms used.
👉 Do you want to know if your devices are subject to FSB Notification? Send us an email to [firstname.lastname@example.org] indicating the tariff codes and we will give you a quick feedback.👈
The Letter of Exemption may be required in customs clearance, which motivates manufacturers to request it and to face a procedure that is exactly identical to that of the Notification. It is a process that is not particularly long (it can be completed in 14 days or even less) but that, to activate, requires the issuance of a Power of Attorney that must have a very specific format and that must be apostilled (recommended option) or processed through the Consulate.
This occurs because only Russian entities can act as “applicant”, as is the case with the EAC certification, with the important difference that the FSB requires that the powers of attorney be notarized and apostilled.
At the end of the procedure, the FSB Notifications will be published on the Eurasian Union website, while the Letters of Exemption cannot be consulted online.
FAC Declaration or Certificate for telecommunication devices
Manufacturers of telecommunications equipment used in public or private networks (communication by radio, cable, telephone, etc.) have to obtain a mandatory certification issued by the Ministry of Digital Development, Communications and Media of the Russian Federation (Министерство цифрового развития, связи и массовых коммуникаций Российской Федерации) that demonstrates the conformity of the devices to the Federal Law on Telecommunications FZ-126 (126-ФЗ). This certification has two forms:
- FAC Declaration of Conformity for telecommunications
- FAC Certificate of Conformity for telecommunications
The Declaration, as usual, is the simplest form of certification: it does not usually require laboratory tests (mandatory in the case of the Certificate) and can be obtained with a validity of up to ten years (instead of three). The law explicitly indicates the telecommunication devices subject to the Certificate: the other devices fall under the assumption of a FAC Declaration of Conformity for telecommunications.
RF Conclusions: an obligation for the importer, or not?
For the import and subsequent use in the Russian Federation of devices such as high frequency receivers and transmitters and / or radio electronic elements, it is necessary to provide the customs authorities with the so-called RF Technical Conclusions (or RFC Statement) issued by the National Radio Frequency Center (Заключения Радиочастотного Центра).
The document confirms the import right and commits the importer to carry out the installation within one year. It is an obligation that, formally, falls on the importer, but that, due to the mandatory tests in an accredited laboratory, involves the exporter who, not only must provide samples of the devices, but must also provide all technical documentation, translated into Russian.
For inquiries about radio frequency equipment, send us an email without obligation: email@example.com, initially providing this short information:
- Tariff heading
- Technical specifications of the products
In our response we will give you first feedback (FSB notification yes or no) and we will indicate what more specific information we need to determine the applicability of the other procedures, including the normal EAC Certification.