Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan share a single set of technical regulations for cosmetics under the Eurasian Economic Union. For a brand owner this means one compliance file can cover a market of roughly 180 million people. It also means the documentation requirements are stricter than most single-country systems. The barrier to entry is rarely the product itself; it is whether the document chain is complete and a local responsible party is in place.

1. The regulatory basis: TR CU 009/2011

Cosmetics in the EAEU fall under TR CU 009/2011 on the safety of cosmetic products. The regulation sets out prohibited and restricted substances, microbiological and physicochemical limits, toxicological assessment requirements, and the information that must appear on the label. TR CU 009/2011 is the foundation for the whole project, and both the formula and the artwork have to be checked against it line by line.

The regulation separates ordinary cosmetics from products with specific requirements, such as sunscreens, whitening products, children's products and oral care. Deciding whether a product sits in the ordinary or the specific category is the first scheduling decision in the project, because choosing wrongly means redoing the entire file.

2. EAC declaration or EAC certificate

Ordinary cosmetics normally follow the EAC declaration route. The applicant, usually an importer or a local legal entity inside the union, registers the declaration in the system on the basis of test reports. Products in the specific category need an EAC certificate issued by an accredited body. A declaration is a self-declared conformity where the applicant carries the liability, while a certificate is backed by an accredited body and involves a deeper review.

A brand without a legal entity inside the union must appoint an authorised representative. That representative's details appear on both the label and the declaration. There is no workable route into the EAEU without a local responsible party, so this should be arranged before any artwork is finalised.

3. When SGR state registration applies

SGR registration applies to categories listed explicitly in the regulation, including children's cosmetics, sunscreens, certain hair dyes and oral care products. A product in these categories needs SGR before it can circulate. SGR and the EAC declaration run in parallel rather than as alternatives, so one does not replace the other.

The SGR review covers the formula, toxicological data and clinical information, and typically takes several months. Treating an SGR review as if it were a routine declaration is the most common reason a launch date slips. Build that period into the plan as a separate line item rather than as a buffer.

4. Labelling: Russian text, mandatory content and the EAC mark

The label must be in Russian; other languages may appear alongside but cannot replace it. Mandatory content includes the product name and purpose, manufacturer and responsible party details, country of origin, batch code, shelf life or period after opening, ingredient list in descending INCI order, net content, storage conditions and any warnings. The ingredient list has to use INCI names in descending order, and trade names or common names will be rejected.

The EAC mark has rules on size, position and legibility, and in practice it needs to appear on the primary pack rather than only on the outer carton. An EAC mark printed only on the folding carton is one of the details most often flagged at border inspection. Reserve the space during packaging artwork rather than applying a sticker later.

5. Documents the factory has to supply

A factory typically provides the formula or a formula statement, raw material specifications and safety data sheets, a certificate of analysis for the finished product, microbiological and physicochemical test data, stability data, and site credentials such as ISO 22716 or GMPC. The completeness of the file decides whether the declaration clears in one pass, and a single missing raw material specification can send it back.

Formula changes must be communicated. The declaration is tied to the formula, so swapping a raw material or adjusting a ratio can invalidate the existing file. Any formula change should trigger an assessment of whether the declaration needs to be re-filed, because retroactive correction costs far more.

Documentation support depends on the destination market, so share the target country and category early. Company background is on the about us page, production credentials are described on the workshop page, reference products are listed under our product range, and export enquiries can be sent through the inquiry form.