Clarifications on certification schemes and involved parties
RUSTANDARD - Product Registration and Certification
GOST R, Gost Russia, Gost Standard, RTN, GGTN

Clarifications on certification schemes and involved parties

09 September 2011

Very often our customers ask us the question of who can be the applicant for the certificates of conformity. We have an official response to this question from Russian Research Institute for Certification "VNIIS". To understand the topic of the subject we will make a brief summary of the certification process exists in Russia today.
We wish to clarify that it is the mandatory certification of products with the release of the "certificate" of conformity and the "statement" of compliance. The latter can be requested and issued only by an entity under Russian law.
The holder of the certificate of conformity is the certification request. The applicant usually is either the manufacturer or importer. Most certification bodies Russians framing this relationship as: if the applicant is a manufacturer it is the "mass production", if the importer is a "supply constant or periodic" framed as part of a contract or bill of sale. Consequently, the manufacturer shall issue a certificate for the manufacture and serial importer a certificate that is bound by contract or sales invoice.
But what happens when an Italian manufacturer does not sell directly to a Russian customer, but to another foreign manufacturer or dealer who then sells or sells the finished product to the customer is not the Russian and serial production, but a single supply?
The answer to this question lies in the match between ourselves and the Institute for Research and enclosing below.

REQUEST FOR CLARIFICATION

Translation from Russian to English.

Moscow, August 9, 2011

Att. Director of "VNIINMASH"
123007 Moscow, ulitsa Shenogina (Shenogin street), 4
Alexander Sergeevich Bubnov

Dear Mr. Alexander,
as part of the certification of products to the undersigned have sprung a series of questions which has not been given a clear answer.
I ask you to answer the following questions:

Question 1
In product certification within GOST R system or as part of technical regulations, a foreign producer can serve as an applicant for certification (subject, from which issued the request)?
Example:
Company "A" (Italian manufacturer) sells the company "B" (exporter, Italian company) an object "X" (delivery of 5 pieces). The company "B" asks the company "A" certificate of conformity. The company "B" in turn sells the product "X" company "C" (Russian importer).
The company "A" may request and obtain the certificate of conformity for the object "X" according to the certification schemes 6c, 7c or 9 GOST R? That is, a foreign producer can act as applicant for the certification of a single document in the supply of products in the absence of a contract or an export invoice with a company or individual entrepreneur Russians?

Question 2
A foreign producer can act as a single applicant in the certification of delivery of products for exploration in Russia under a contract of sale or invoice (single supply)?

Thanking you in advance I offer you my cordial greetings,

Roman Maluntsev
+7 926 3315239

Mailing Address:
127254 Moscow
Ulitsa Goncharova
(Goncharov street), 27, apt. 27

RESPONSE

Translation from Russian to English.

Russian Research Institute for the Certification
Privately Held
(JCS VNIIS)
Elektrichesky pereulok (alley of Electricity), 3 / 10, building 1
Moscow 123557
Phone: +7499 2537060 Fax: +7 499 2533360
Website www.vniis.ru e-mail: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Prot. No. 101-KS/1270 of 02/09/2011

Ref. No. letter ---
of 09/08/2011

Att. Roman Maluntsev
127254 Moscow
Ulitsa Goncharova
(Goncharov street), 27, apt. 27
Tel +7 926 3315239

CONSULTATION

In reference to your request on the possibility for a foreign producer to act as applicant for certification of export commodities on the territory of the Russian Federation, we want to specify the following:
The Federal Law "On technical regulation" No 184 of 12.27.2002 (with subsequent amendments and additions: Federal Law No. 45 of 09/05/2005, No. 65, 01/05/2007, No. 309, 01/12/2007, No. 160 of 23/07/2008, No. 189, 18/07/2009, No. 261, 23/11/2009, No. 384, 30/12/2009, No. 385 of 30/12/2009, No. 243 of 28/09/2010) provides no limitation for foreign producers or dealers to act as requiring the certification of products subject to mandatory certification (as opposed to the request for a declaration of conformity, Art. 24). At the same time, some technical regulations currently in force include limitations, similar to those required for the declaration of conformity (only one subject being the place of the foreign producer).
That said, foreign manufacturers or dealers may act as applicant for certification if the current technical regulations do not specify otherwise, or where the products are subject to mandatory certification as required by Resolution of the Government of the Russian Federation No 982 of 01/12/2009 (with subsequent amendments and additions: Resolution of the Government of the Russian Federation No. 148 of 17/03/2010, No. 149, 17/03/2010, 548 of 26/07/2010 , No. 848 of 20/10/2010, No. 906 of 13.11.2010).
With regard to certification schemes, their implementation does not depend on the origin of products (local or imported). It follows that if a manufacturer or dealer can pretend to be foreign applicant for certification, he may well present the application for certification of a single contract, provided with a contract or a sales invoice.

The Deputy Director General    <signature illeggibile>    I.M. Feldman

/Round Stamp: VNIIS, Scientific and Research Institute for Certification (VNIIS JSC), Moscow, Company, Reg Set 1047703024698, CF 770338058, Cod Iscriz reason. Reg Imp 770301001, certificate of conformity No stamp (PechatSert) PC.RU.P.001 2004.07/

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