Time to export to the Eurasian Union: what you need to know about the EAC Marking

Spanish cosmetics in Russia: a booming market despite everythingThey have managed (with difficulty) to do without Spanish ham, and even after a few years, Spanish machinery; but what the Russians are not yet able to give up is Spanish cosmetics.According to Trade Economics data, in 2024 the cosmetics sector has led Spanish exports to Russia. In relative terms, levels of 2021 have been exceeded by 22%, when the invasion of Ukraine had not yet begun. This data is really remarkable if we consider that, in the same period of time, Spanish machinery exports have been reduced by 83%.The reason is simple: European cosmetics (as well as products from another important sector, fashion) are not subject to EU sanctions and can continue to be sold without restrictions in department stores in Moscow, St. Petersburg and other Russian cities and, increasingly, in specialized web portals.This is a market that, despite the geopolitical, economic and war context, is still very dependent on imports and positively values Spanish brands, although these hold a market share that is only a third of that of French or Korean brands.The EAC Marking: key to accessing the Eurasian UnionIn short, everything indicates that there are conditions for new Spanish brands to access this market, and for those that already operate to consolidate their position. In both cases, they must have a strategy on how to address the EAC marking, which is an essential requirement to sell in the Eurasian Union, an economic space in which 180 million people live and which is formed by Russia, Belarus, Kazakhstan, Kyrgyzstan and Armenia. By the way, Belarus and Kazakhstan are also booming markets, although the penetration of Spanish cosmetics in them is still incipient.In order to put the EAC logo on the packaging or on the product itself, the manufacturer has to demonstrate compliance with the CUTR 009/2011 regulation, which has important similarities with Directive (EC) 1223/2009 in the safety and use of ingredients requirements, but not in the certification procedure which is totally different.The Eurasian regulation requires that each cosmetic be tested in an accredited Russian laboratory or from any country of the Union. The favorable test report will allow the registration of the product, either under the form of EAC Declaration of Conformity, or under that of the State Registration Certificate (SGR), which is required for a set of 13 categories of products considered more potentially dangerous.The one who will request the certification will not be the manufacturer (even if it is legally responsible for any non-conformities of its products) but the applicant, or applicant, who will always be a company located in the Eurasian Union.But who is in charge of the EAC marking?The applicant is usually either the Eurasian importer or a specialized company that acts under the mandate of the manufacturer. In the first case, the importer-distributor assumes the costs and, in this way, ensures ownership of the certification.The manufacturer or another importer can always request another certification, but it will mean repeating the process from scratch.Depending on the level of penetration in the market, the number of importers and the relationship with them, a manufacturer will choose to get involved or not in the certification process and hire a specialized company. A factor to take into account will be the degree of confidence and protection of industrial secrets, since at any time it may be necessary to deliver the exact composition of the cosmetic to the certification body, especially in the case of the State Registration Certificate (SGR).So much for the theory. In another article we will talk about recent developments that have affected Russian laboratories, the "logistics of samples" and other factors to take into account when obtaining the EAC marking.

Time to export to the Eurasian Union: what you need to know about the EAC Marking

While other exports plummet, Spanish cosmetics conquer Russia: regulatory keys and opportunities in the Eurasian Union

Roberto Cordano

Trade Product Compliance