Exports to Russia: clarification on GLN and GTIN codes

The requirement of the GLN and GTIN codes was introduced for the first time in the Russian certification field with the order of the Ministry of Economic Development of the Russian Federation of 31.07.2020 No. 478. This order sets out an EAC declarations of conformity registration procedure in the Russian national database. For manufacturers outside the Eurasian Union, in addition to the data usually entered, the obligation to enter GLN and GTIN code was introduced starting from 01.01.2021 (date of entry into force of the aforementioned order).

The GTIN code (Global Trade Item Number) is a barcode present on the packaging of consumer goods distributed to the public through large retailers. The GLN (Global Location Number) is a derivative thereof or vice versa that identifies the manufacturer, its registered office, production plants, secondary offices and local units, etc.

This innovation has aroused strong protests into a Russian business community, so much so that it forced the Russian Ministry of Economic Development to modify the initial text of the order at the last minute. On 30.12.2020 with order No. 877 the obligation of the GTIN code has been partially removed, specifying that it should only be indicated if available, while the obligation to indicate the GLN has been postponed until 01.07.2021.

However, the controversies have not subsided and this time they have also involved the Eurasian Economic Commission where in the debate, the innovation proposed by the Russian authorities has again been the subject of strong criticism.

Considered the reaction of the trade associations and the outcome of the debates at the Eurasian Commission level, the Russian government had to issue Decree No. 936 of 19.06.2021, with entry into force from 21.06.2021, with which it removed the obligation of the GTIN, specifying that its indication is optional, and allowed the geographical coordinates (latitude and longitude) of the production site (production sites) to be indicated as an alternative to the GLN, detected through the GLONASS system (Russian analogue of the American global positioning system, known by the acronym of GPS). Therefore, instead of the GLN it is sufficient to indicate the geographical coordinates, for example, found using Google Maps.