Exporting Packaging to Russia: 3 Real EAC Compliance Requirements — GOST-R / TR TS / EAC Marking

Last winter, a printing company in Zhejiang that produces tea gift boxes received an order for Russia—20,000 gift boxes—and printed the GOST-R mark according to the customer’s specifications. The goods were rejected by Moscow customs. The problem was not GOST-R itself, but the TR TS 005/2011 “Safety of Food Contact Packaging” technical regulation—the gift boxes used PVC film as liners, while Russian regulations permit only PE food contact at temperatures below 80℃. The customer did not request a material change, and the printing company did not verify the requirements either. As a result, all 20,000 gift boxes had to be returned, and the printing company bore approximately 320,000 yuan in freight, reselection of materials, and reprinting costs.

Packaging compliance in Russia and the EAEU union—Russia, Belarus, Kazakhstan, Kyrgyzstan, and Armenia—follows a “three-track system”: a) GOST-R national standards (voluntary certification); b) TR TS Customs Union technical regulations (mandatory); and c) EAC marking (conformity assessment mark). These three sets of rules apply in different circumstances, and printing companies must distinguish between them when handling orders for Russia. Since 2025, this has been the largest compliance pitfall in exports to Russia.

Category 1: GOST-R National Standards vs EAC Mandatory Certification

GOST-R is Russia’s national standard system (ГОСТ Р), which dates back to the Soviet period and continues today. However, since 2023, the GOST-R system has been merging with the EAC system. In other words, most products that previously required GOST-R certification now require EAC certification. When a printing company receives an order for Russia, the first step is to ask the customer: “Does your product require EAC certification or GOST-R certification?”

Practical differences: ① EAC certification is recognized across all 5 EAEU member states; ② GOST-R certification is recognized only in Russia; ③ EAC certification requires a local representative in Russia (applicant), whom the customer will generally engage through an agency; ④ GOST-R certification can be applied for directly by a foreign applicant. The costs and timelines of the two certifications differ by approximately 30%-50%.

A common mistake in practice is that the customer’s artwork includes a GOST-R mark, while the customer’s product actually requires EAC certification. In this case, the printing company may focus only on printing rather than certification, but if the printed mark does not match the actual certification, customs inspections may determine that the “mark does not correspond to the product.” At the prepress verification stage, printing companies must request a copy of the certification certificate from the customer and check whether the brand and artwork are consistent. When the correct status cannot be determined, it is recommended that the party responsible for payment present the original certificate upon delivery.

Category 2: TR TS Technical Regulation for Food Contact Packaging

TR TS 005/2011 is the EAEU union’s unified technical regulation for food contact packaging and took effect on July 1, 2012. The regulatory list restricts 9 categories of materials: paper, paperboard, 瓦楞, plastics PE/PP/PET, glass, ceramics, metals, wood, and textiles. Each material category has clear limits for heavy metals, migration levels, and specific monomers. For paper, the limits include lead ≤ 0.5mg/kg, cadmium ≤ 0.1, mercury ≤ 0.02, and hexavalent chromium ≤ 0.05; for plastics, total migration must be ≤ 10mg/dm², with specific monomers (styrene and vinyl chloride) ≤ 0.01mg/kg.

For the common food packaging types printed by printing companies: ① PE-coated paper box liners are compliant; ② PVC film liners used for blister packaging are non-compliant and must be replaced with PET or PE; ③ aluminum foil liners used for biscuit boxes require a coating on the surface; ④ EVA liners used in premium gift boxes are not accepted by TR TS 005 for direct food contact and require an inner PE barrier layer.

During prepress verification, printing companies should ask the customer: “Does the product come into direct contact with food?” If it does, material selection must strictly follow the TR TS 005 list rather than being decided arbitrarily by the customer. Many printing companies print PVC as soon as the customer specifies PVC without checking TR TS 005, resulting in returned shipments.

Category 3: 3 EAC Marking Formats vs 3 Placement Requirements

The EAC mark is the EAEU union’s unified conformity assessment mark—3 Cyrillic letters, EAC, arranged in a circular logo. Regulations require the mark to appear on the product itself or its smallest sales package, be clearly recognizable, and, as a rule, be applied independently to each product. It cannot be “marked only once on a large outer carton.”

There are 3 common mistakes made by printing companies: ① Incorrect mark placement—under Russian regulations, the EAC mark must appear on the sales packaging itself, where consumers can see it immediately. Some printing companies instead place it on the shipping carton following the practice used for domestic exports, resulting in an “incorrect mark placement” finding during inspection. ② Incorrect mark dimensions—the mark must be no less than 5mm in diameter. Some gift box layouts are compact, and the mark is compressed to less than 3mm, making it invalid according to customs. ③ Incorrect mark color—the mark must use a single color, either black or white, and must not blend into the brand colors. Some customer designs use an “accent color” to incorporate the mark into the brand logo, creating a significant compromise if the printing company reproduces it directly.

Printing companies should add a dedicated “EAC Marking Verification Checklist” to the prepress verification form, with 5 mandatory fields: placement / size / color / clearance from other certification marks / independent recognizability. Each field must be signed by the prepress inspector, and unsigned orders should not enter production.

Further Reading

• Exporting Food Packaging to Southeast Asia: 3 Special Requirements—Halal/Vietnamese TCVN/Indonesian SNI
• Exporting Packaging to the EU: 4 Compliance Requirements—REACH/EC 1935/2004/94/62/EC/EN 13427
• Exporting Packaging to the United States: 4 Requirements—FDA/UL/Proposition 65/CPSIA

The Fourth Item Often Missed on Orders for Russia: The Layer After Printing

The first 3 categories are matters of eligibility—whether you are qualified to handle the order. However, what most often causes failures for printing companies operating in the Russian supply chain is the execution layer after eligibility: how the goods are shipped, whether the marks are correct, and how the documents are retained.

First, consider whether shipping packaging marks must match sales packaging. Under Russia’s compliance logic, the mark must, in principle, appear on the “product itself or its smallest sales package.” In practice, an outer carton may contain dozens of smallest sales packages, so the outer carton usually carries only shipping marks (唛头) and no EAC mark. A common printing company mistake is to print both—an EAC mark on the outer carton and another on every small box. As a result, the EAC mark on the outer carton is compressed into the shipping layout to a diameter of less than 5mm and is therefore invalid. Customs inspectors see the invalid mark on the outer carton. This is a typical case where “printing more actually creates a violation.”

Our current practice is to ask “Which layer is the smallest sales package?” before proofing orders for Russia. If the customer’s product is a gift box, the gift box is the smallest sales package, and the EAC mark is printed on the gift box. If the product is placed in boxes and the outer cartons are placed directly on retailer shelves, the outer carton is the smallest sales package. The EAC mark appears in entirely different locations and layout positions in these two cases.

Second, consider document retention periods. Printing companies must retain copies of certification certificates, material declarations of conformity, and approved artwork for orders for Russia. The retention period should cover the customer’s sales cycle. Gift box orders may have sales cycles extending across years, while pharmaceuticals and children’s products take even longer. Our factory’s practice is to scan and archive the approved artwork and copies of certificates, store them together with the order records, and retain them for 3 years. This is not because the regulations require 3 years, but because when a problem occurs, what is often needed is not the certificate itself, but the correspondence between “the certificate copy you obtained at the time” and “the version of the artwork you printed at the time.”

The third item is document language. If the accompanying documents for an order for Russia are in English, a Russian version will generally need to be added in practice. The EAC mark itself uses the Latin letters EAC and does not raise this issue, but the acceptance of English or Chinese packaging copy involving product descriptions, ingredients, and warnings in the Russian market is a separate matter. Printing companies are often not told about these requirements during initial contact and only discover them during prepress verification, when the artwork must be rearranged—the copy area changes from 1 line to 2, requiring changes to the entire layout. At the quotation stage, printing companies should ask: “Will the packaging need Russian-language instructions? Will the customer provide the Russian text, or do we need to translate it?”

Taken together, the prepress verification form for orders for Russia is effectively a 5-column table: certification type (EAC or GOST-R), whether the material is on the TR TS 005 list, mark placement and dimensions, which layer is the smallest sales package, and the language of supporting documents and copy. The first 3 columns determine what is printed, while the last 2 determine where it is printed and how many times. The order cannot be reversed—first determine the certification type to know what the mark should look like; then determine the smallest sales package to know where the mark layout should be placed.

Finally, a practical note for colleagues handling orders for Russia: the most expensive aspect of these requirements is not fines, but returned shipments. A batch of gift boxes shipped from Ningbo Port to Moscow for customs clearance travels by land or sea, with its value tied up on the ocean or railway and the customer’s production schedule completely disrupted. Asking a few more questions at prepress costs one phone call. Failing to ask them can cost an entire container’s freight plus a pile of rework. There is no need to calculate this precisely; simply remember that the return cycle is measured in “weeks,” not “days.”