Importation of cryptographic devices. Notifications

Legislation of the Eurasian Economic Union (EAEU) restricts importation and exportation of cryptographic devices. Common goods which have cryptographic functions (e.g. laptops, mobile phones, routers, certain types of software etc.) thus can only be imported after the customs is provided with so-called Notification.

The products with cryptographic functions are listed in the Decision of EAEU Commission № 30 of 21 April 2015 (Appendix 2, Paragraph 2.19). Russian importers and customs agents just say: “the product falls under 2.19 list”.

What is Notification?

Registered notification

The notification is a document which contains information about cryptographic functions of the products (e.g. authentication, Wi-Fi encryption etc). Namely, it should describe every cryptographic algorithm used by the product as well as respective key size and cryptographic protocol.

Who draws up Notification?

The notification is to be executed and signed by an importer/exporter (EAEU company) or manufacturer (it can be a non-EAEU company) and then submitted to the national security body of one of EAEU member-countries. The security body registers the Notification within 7 working days. After that the Notification is considered to be “ready to use”.

Who can use Notification?

As soon as the Notification for certain product is registered by security body (e.g. FSS) it is published on the official website of EAEU Commission. After that any EAEU company can import the product to the EAEU. The only thing they need to do is to provide customs with the Notification ID-number.

Is there already a Notification for your product?

In order to check if there is already a Notification for certain product registered please visit EAEU Commission website and try to find your product in the Register.

Should you have any problems do not hesitate to contact our specialists, we will provide you with our help.

If your product is not included into the Notification Register we would be happy to help you to register the Notification. In particular, we will do the following:

  1. Draw up the notifications for your products considering all information which is necessary for registration by FSS.
  2. Submit notifications to FSS.
  3. Negotiate with FSS officials on the issues of registration.
  4. Obtain the registered notifications at FSS and send them to you.

And what about products without encryption?

There is much more uncertainty in respect of complex devices which do not have any cryptographic functions (e.g. wired printers, wired routers). Such products should not be considered as “cryptographic devices” and thus do not require Notification for import into (export from) EAEU. Nevertheless, the Paragraph 2.19 contains the customs codes of a great number of electronic devices (just because they may “potentially” use cryptographic algorithms). According to official instructions of Russian Federal Customs Service, in case of importation of such devices local customs bodies should analyze technical documentation (issued by the manufacturer) and find out if the products actually contain crypto functions (algorithms) or not.