Product Certification for Kazakhstan in 2026: When You Need a Declaration of Conformity, the EAC Mark and What a Mistake Costs

To sell goods lawfully in Kazakhstan you usually need a registered declaration of conformity rather than a certificate — and only a company registered in Kazakhstan or another EAEU member state can obtain one. A foreign manufacturer cannot be the applicant in its own name: it needs either a person authorised by the manufacturer or a resident importer. Whether conformity is confirmed by declaration or by certification is decided not by the seller but by the particular technical regulation that covers the goods.

As at September 2026 the EAEU has adopted 53 technical regulations, of which 48 are in force. On the Committee for Technical Regulation and Metrology’s own figures they cover more than 85% of the products circulating on the market.

The principal risk of 2026 is a “grey” document bought without testing. In May 2026 Kazakhstan invalidated 1,113 certificates and declarations issued in EAEU states: 742 in Kyrgyzstan, 244 in Russia and 11 in Belarus. In the first half of 2026 the Committee’s territorial departments cancelled more than 42,000 conformity confirmation documents. Checking takes two minutes: if the document is not in the register, the goods count as released into circulation without conformity assessment, and that carries a fine of up to 600 MCI(the monthly calculation index) for a large enterprise and up to 1,200 MCI on a repeat offence.

What follows is the whole structure: the two tiers of regulation (the Union and Kazakhstan), the six standard declaration schemes, who may be the applicant, the time limits and cost of each procedure, the rules for applying the EAC mark, the registers, evidence retention, state supervision and the actual level of fines under the Kazakh Administrative Offences Code.

Nine facts worth carrying into the rest of this article:

•          53 technical regulations have been adopted in the EAEU and 48 of them are in force as at September 2026.

•          5 regulations have been adopted but are not yet in force: TR EAEU 039/2016, 041/2017, 047/2018, 048/2019 and 053/2026.

•          3 working days is the maximum period for registering a declaration of conformity with an EAEU technical regulation.

•          5 working days is the maximum period for registering a national Kazakh declaration of conformity.

•          No more than 5 years is the maximum validity of an EAEU declaration for serially produced goods; for a batch no validity period is set at all.

•          10 years is the retention period for the evidence file held by the applicant under Union law where the technical regulation says nothing else.

•          No less than 5 mm is the minimum base size of the EAC mark.

•          600 MCI (KZT 2,595,000) is the fine on a large enterprise for releasing goods into circulation without conformity assessment documents; 1,200 MCI (KZT 5,190,000) on a repeat offence within a year.

•          KZT 4,325 is the monthly calculation index applied in Kazakhstan from 1 January 2026.

Two tiers of regulation: what the Union decides and what Kazakhstan decides

Mandatory requirements for goods sold in Kazakhstan are set at two levels: supranational, through the technical regulations of the Eurasian Economic Union, and national, through the legislation of the Republic of Kazakhstan.The first level prevails: where a Union technical regulation has entered into force, national requirements for the same product no longer apply.

The legal foundation of the upper tier is the Treaty on the Eurasian Economic Union of 29 May 2014, Section X, together with the Protocol on technical regulation within the Eurasian Economic Union, Annex No. 9 to that Treaty. It is the Protocol that supplies the definitions, the procedure for adopting regulations, the forms of conformity assessment and the rules on circulation of goods.

What the Protocol on technical regulation says

Paragraph 3 of the Protocol states the boundary directly: “For objects of technical regulation in respect of which technical regulations of the Union have not entered into force, the norms of the legislation of the member states or acts of the Commission apply.” That is the key to the whole structure: the moment a Union regulation enters into force, a national technical regulation on the same subject stops applying; until it does, Kazakh law governs.

Paragraph 2 of the Protocol contains a definition that many sellers read too narrowly. “Release of products into circulation” means “supply or import of products (including dispatch from the manufacturer’s warehouse or shipment without warehousing) for the purpose of distribution on the territory of the Union in the course of commercial activity, whether for consideration or free of charge”. Shipping a batch from the manufacturer’s own warehouse is already a release into circulation. So is handing goods over free of charge, for instance as display samples for retailers.

Paragraph 6 of the Protocol creates the marking obligation: “Products complying with the requirements of the technical regulations of the Union applicable to them, and which have passed the conformity assessment procedures established by the technical regulations of the Union, are subject to mandatory marking with the single mark of product circulation on the market of the Union.” The same paragraph requires the marking to be in Russian when the goods circulate within the Union and, where the legislation of a member state so requires, in that state’s state language as well.

The amendment chain: three operative revisions and one deferred

The Protocol on technical regulation is not a settled text. Between 2019 and 2025 it was amended by four protocols; three of them are in force, and the fourth is signed but not operative.

Note the gap between signature and entry into force for the 2022 Protocol: almost two years. That is normal for instruments amending a founding treaty, and it explains why a good deal of commentary published in 2022 and 2023 describes rules that were not yet operative.

The lower tier: Kazakh statute

The national level rests on the Law of the Republic of Kazakhstan of 30 December 2020 No. 396-VI “On technical regulation”. It was adopted on 30 December 2020, first officially published on 31 December 2020 in Kazakhstanskaya Pravda (No. 250 (29377)) and, under paragraph 1 of Article 48, brought into operation six months after first official publication — that is, on 1 July 2021. Paragraph 2 of the same Article repealed its predecessor, the Law of 9 November 2004 bearing the same title.

Paragraph 2 of Article 2 settles the hierarchy expressly: “If an international treaty ratified by the Republic of Kazakhstan establishes rules other than those contained in this Law, the rules of the international treaty apply.” In practice that means: where Law 396-VI and an EAEU instrument diverge on a matter governed by the Treaty, Union law prevails.

How many EAEU technical regulations are in force in 2026

As at September 2026 the Eurasian Economic Union has adopted 53 technical regulations, of which 48 are in force.Both figures can be verified in two independent ways: by counting the entries in the Eurasian Economic Commission’s own registers, and against a statement by the Kazakh regulator.

The Commission’s register of adopted technical regulations lists 53 entries, running from TR CU 001/2011 to TR EAEU 053/2026. The register of technical regulations in force lists 48.

On 10 July 2026, at a press conference at the Central Communications Service under the President of the Republic of Kazakhstan, the acting chairman of the Committee for Technical Regulation and Metrology of the Ministry of Trade and Integration, Bauyrzhan Kasymov, said, word for word: “Within the Eurasian Economic Union 53 technical regulations have been adopted, of which 48 are already in force and govern more than 85% of the products circulating on the market.”

The five regulations adopted but not yet operative

The difference between 53 and 48 is five regulations adopted by the Council of the Commission but not yet in force. Knowing which they are matters: the products they will one day cover are today governed either by the Unified List or by Kazakh national law.

The newest regulation: paints and varnishes

TR EAEU 053/2026 “On the safety of paint and varnish materials” was adopted by Decision of the Council of the Eurasian Economic Commission of 20 May 2026 No. 65. The decision was published on 1 July 2026 and entered into force on 31 July 2026; the regulation itself starts to operate later, on 1 January 2028.

Keep these dates apart: the decision was adopted on 20 May 2026, published on 1 July 2026 and entered into force on 31 July 2026, while the regulation itself enters into force on 1 January 2028. Conflating them is the single most common error in reporting on new regulations.

Paragraph 2 of Decision No. 65 also contains a deferred rule inside a deferred regulation: the limit on lead content calculated on dry residue under paragraph 12 of the regulation takes effect 60 months after the regulation itself enters into force, and not before the relevant interstate standards are added to the list of standards. For the first 36 months a transitional limit of no more than 0.5% applies.

For Kazakh manufacturers this regulation has a further dimension: according to Bauyrzhan Kasymov it was approved at Kazakhstan’s initiative.

Alcohol: moved to 2027

Decision of the Council of the Eurasian Economic Commission of 20 May 2026 No. 62 moved the entry into force of TR EAEU 047/2018 “On the safety of alcoholic products” from 1 July 2026 to 1 January 2027. The operative wording could hardly be terser: in paragraph 2 of Decision of the Council of the EEC of 5 December 2018 No. 98, “the words ‘from 1 July 2026’ shall be replaced by the words ‘from 1 January 2027’”. The amending decision itself entered into force on 10 July 2026.

The practical consequence for alcohol importers: until 1 January 2027 conformity confirmation of alcoholic products in Kazakhstan runs on national rules, not on the Union regulation.

What falls outside the EAEU technical regulations

Union technical regulations cover more than 85% of products, but not all of them. What remains splits into three groups: products on the Unified List, products under Kazakhstan’s own technical regulations, and products taken out of technical regulation altogether. Confusing these groups means either paying for a procedure you do not need or reaching the market without a document you do.

Group one: the Unified List

Paragraph 7 of the Protocol on technical regulation preserves a transitional mechanism for products not yet covered by a Union regulation where member states’ mandatory requirements coincide. Such products may circulate within the Union if they have passed conformity confirmation in a member state on these conditions: certification by a body included in the single register of Union conformity assessment bodies, and testing in laboratories from that same register.

The list of such products is approved by Decision of the Customs Union Commission of 7 April 2011 No. 620. The decision has been in force since 27 May 2011 and has not been repealed.

One detail is missed by almost every commentary: the current title of this decision differs from the original. In its 2011 wording it was “On the Unified List of products subject to mandatory conformity assessment (confirmation) within the Customs Union with the issue of single documents”. By Decision of the Council of the Eurasian Economic Commission of 18 October 2016 No. 146 the title became “On the Unified List of products subject to mandatory confirmation of conformity with the issue of certificates of conformity and declarations of conformity in a single form”. Citing the old title in 2026 means citing a version that no longer exists.

Decision No. 620 has been amended nineteen times. The most recent amendment was made by Decision of the Council of the Eurasian Economic Commission of 19 August 2022 No. 119.

Group two: Kazakhstan’s own technical regulations

Where no Union regulation exists, a technical regulation of the Republic of Kazakhstan applies. These are now approved by order of the relevant minister and registered with the Ministry of Justice — unlike the practice before 2020, when they were adopted by government resolution.

The regulator itself supplied a live 2026 example. In Bauyrzhan Kasymov’s words, “at national level, in March of this year the technical regulation of the Republic of Kazakhstan ‘Requirements for coal and its processing products’ entered into force”. That regulation was approved by order of the Minister of Industry and Construction of the Republic of Kazakhstan of 11 March 2025 — a year between approval and commencement. Coal is covered by no EAEU regulation, so the national regulation here does not duplicate a Union instrument; it fills a genuine gap.

There is no publicly available count of the technical regulations of the Republic of Kazakhstan in force.The “Technical regulations of the RK” section of the digital technical regulation system requires authorisation, and the Committee’s official briefings in 2026 give figures for EAEU regulations, standards and accredited bodies but not for national regulations. This was checked on 16 September 2026. Any round number of the form “Kazakhstan has N technical regulations in force” that you come across online is not supported by an official source.

Group three: products outside technical regulation altogether

Paragraph 2 of Article 3 of Law 396-VI removes a whole series of categories from the objects of technical regulation. This is not a concession or a simplification — it is a different regulatory regime, and often a stricter one.

This version of Article 3 reflects the amendment made by the Law of the Republic of Kazakhstan of 1 July 2024 No. 104-VIII, brought into operation sixty calendar days after first official publication.

The most common practical error here concerns medical devices. An importer sees a product on a pharmacy shelf bearing the EAC mark, concludes that a declaration is needed and approaches a conformity confirmation body. In fact medical devices are outside the Law on technical regulation and undergo state registration within the healthcare system. The EAC mark on such goods relates either to other products of the same supplier or to a regulation the product falls under on a different footing — as electrical equipment, for instance.

Declaration or certificate: who chooses the form

The form of conformity confirmation is chosen neither by the seller nor by the conformity confirmation body, but by the technical regulation. (“Conformity confirmation body” renders the Kazakh term орган по подтверждению соответствия, a national institution; it is not the same as the Union’s wider class of conformity assessment bodies, which also takes in testing laboratories.) Paragraph 3 of Article 26 of Law 396-VI puts it flatly: “Mandatory confirmation of conformity is carried out only in the cases established by the relevant technical regulation and exclusively as to compliance with its requirements.”

Paragraph 1 of Article 25 names both forms: confirmation of the conformity of products with the requirements established by technical regulations is carried out by adopting a declaration of conformity and (or) by carrying out certificationand issuing a certificate of conformity.

What actually separates a declaration from a certificate

The difference is not one of “difficulty” or of the document’s standing, but of who makes the assertion of conformity.

The conclusion that matters for a project budget: a declaration is cheaper not because it is “easier” but because the applicant does part of the evidential work itself. Responsibility for that work is entirely the applicant’s.

When the declaration route is barred

Paragraph 3 of Article 25 of Law 396-VI sets out an exception that is rarely flagged in advance: “Confirmation of the conformity of a technically complex article and (or) a technically complex product with mandatory requirements is carried out in the form of certification”, with test reports submitted for the structural components of such an article unless the technical regulations provide otherwise.

Movement in the other direction is possible. Paragraph 110 of the standard conformity assessment schemes approved by Decision of the Council of the EEC of 18 April 2018 No. 44 allows that “the declaration-of-conformity procedure may be replaced by certification at the applicant’s wish where the technical regulation so provides”. The standard schemes make no provision for the reverse substitution — certification replaced by the declaration route.

A third document: the declaration of general safety

Kazakhstan has an instrument that Union law does not: the declaration of general safety. Article 27 of Law 396-VI describes it as a document issued in respect of products not included in the Unified List, and also products included in the Unified List but for which technical regulations have not been adopted or brought into operation.

Three of its features are worth remembering:

A declaration of general safety is adopted on a voluntary basis by the manufacturer, the person authorised by the manufacturer, the importer or the seller, and is entered into the digital technical regulation system on the basis of a notification from the person who adopted it.

Voluntary application of national standards whose scope extends to the products being released into circulation is a sufficient condition for ensuring the general safety of the product — paragraph 3 of Article 27. This is an unusual provision: the statute expressly treats a voluntary standard as sufficient evidence.

The basis consists of national standards and (or) other standardisation documents, and (or) technical documentation, and (or) the results of research (testing) and measurement — paragraph 4 of Article 27.

The register of declarations of general safety is kept separately from the register of declarations of conformity and is available in the digital technical regulation system.

When no mandatory confirmation is required at all

Paragraph 4 of Article 26 of Law 396-VI takes three categories outside mandatory confirmation of conformity, unless technical regulations provide otherwise:

•          second-hand products;

•          products imported for an exhibition and without being put to their intended use;

•          products supplied as humanitarian aid.

The qualification “unless technical regulations provide otherwise” is not a formality: individual Union regulations set their own requirements for second-hand products, and the national rule does not contradict them but yields to them.

Who may be the applicant: the trap that catches foreign manufacturers

A foreign manufacturer cannot adopt a declaration of conformity for the Kazakh market in its own name. The applicant must be a person registered under the legislation of the Republic of Kazakhstan or of another EAEU member state. This is not custom or practice — it is the express wording of the statute and of the standard schemes.

What the Kazakh statute says

Article 1 of Law 396-VI defines a “person authorised by the manufacturer” as a legal entity or individual entrepreneur “registered in accordance with the legislation of the Republic of Kazakhstan or of a member state of the Eurasian Economic Union” which, on the basis of a contract with the manufacturer, including a foreign manufacturer, acts on that manufacturer’s behalf in conformity assessment and in releasing products into circulation on the territory of the Republic of Kazakhstan.

An “importer” is defined in the same Article as a legal entity or individual entrepreneur registered in Kazakhstan or in a member state which has concluded with a foreign manufacturer (seller) a foreign trade contract for the supply of products produced in batches and which releases those products into circulation in Kazakhstan.

Note how the definition of importer is built: it is tied to batches. That is not accidental, and the next paragraph explains why.

The rule in paragraph 1 of Article 17: different applicants for series and batches

Paragraph 1 of Article 17 of Law 396-VI allocates the roles for certification, and paragraph 8 of the same Article does the same for declarations.

Paragraph 8 of Article 17 is worth quoting in full: “On import into the territory of the Republic of Kazakhstan of serially produced products, a declaration of conformity adopted by the person authorised by the manufacturer is recognised. On import into the territory of the Republic of Kazakhstan of products produced in batches, a declaration of conformity adopted by the importer is recognised.”

The same restriction at Union level

The standard conformity assessment schemes approved by Decision of the Council of the EEC No. 44 reproduce this logic through the range of applicants permitted under each scheme. Declaration schemes 1d and 3d (serial output) admit only the manufacturer or a person authorised by the manufacturer. Schemes 2d and 4d (a batch or a single article) add the seller (importer). Schemes 5d and 6d again admit only the manufacturer or the authorised person.

The direct practical conclusion: an importer cannot declare serial output. It can only declare a specific batch or a single article.

The contract with the manufacturer as a mandatory document

Where the applicant is a person authorised by the manufacturer, the document set includes one item that nothing else can substitute for. Sub-paragraph (c) of paragraph 5 of the Procedure approved by Decision of the Board of the EEC of 20 March 2018 No. 41 requires a copy of the contract with the manufacturer (including a foreign manufacturer) providing for ensuring the conformity of products supplied to the customs territory of the Union with the requirements of the technical regulation, and for liability for non-conformity of such products with those requirements.

Two terms in that contract are mandatory on the face of the provision: assurance of conformity and liability for non-conformity. An ordinary distribution agreement containing neither leaves the document set incomplete — and paragraph 12 of the same Procedure makes an incomplete set a free-standing ground for refusal of registration.

For companies only now entering the Kazakh market and still deciding what structure to work through, the choice of presence also determines who can be the applicant. There is a hard constraint here: paragraph 3 of Article 43 of the Civil Code of the Republic of Kazakhstan provides that branches and representative offices are not legal entities, while Article 1 of Law 396-VI requires the importer and the authorised person to be a legal entity or an individual entrepreneur. Those structures are examined in LLP in Kazakhstan for foreigners and Branch and representative office of a foreign company versus an LLP; selecting and registering the right vehicle is what UPPERSETUP’s company registration serviceis for, and the Kazakhstan country page sets out the operating regimes in the round.

The six standard declaration schemes: 1d, 2d, 3d, 4d, 5d and 6d

The declaration scheme determines three things: who may be the applicant, where testing is carried out, and whether production control is required. The schemes are set out in the standard conformity assessment schemes approved by Decision of the Council of the Eurasian Economic Commission of 18 April 2018 No. 44. The decision was adopted on 18 April 2018, published on 18 June 2018 and entered into force on 18 July 2018.

Since adoption it has been amended four times: by Decisions of the Council of the EEC of 23 December 2020 No. 127, 21 January 2022 No. 8, 15 July 2022 No. 107 and 25 January 2023 No. 11.

The schemes side by side

What each scheme means in practice

Scheme 1d is the lightest on formality and the heaviest on responsibility. The applicant assembles the document set, carries out identification and sampling itself or through a certification body, and may test in its own laboratory. The manufacturer must operate production control and “take all necessary measures to ensure that the production process is stable”.

Scheme 2d is for a batch. It contains a provision that saves money on repeat supplies: where the technical regulation permits test results to be used for subsequent batches of similar products, the applicant carries out identification of the batch to establish similarity, and where similarity is established, sampling and testing are not carried out. The validity of the test report used is then set by the technical regulation.

Scheme 3d differs from 1d in one respect: testing only in an accredited laboratory. It is the scheme that most often appears in regulations covering products of medium risk.

Scheme 4d stands to 2d as 3d stands to 1d: the same batch, but an accredited laboratory is compulsory. The rule on similar batches applies here too.

Scheme 5d is the only declaration scheme in which a certification body plays a substantive role. It carries out a product type examination and, where the result is positive, issues a product type certificate in a single form. The key provision reads: “The product type certificate is an integral part of the declaration of conformity.” Loss or annulment of the type certificate automatically hollows out the declaration.

Scheme 6d is for manufacturers with an implemented and certified management system. It has a built-in self-destruct mechanism that is worth knowing about in advance: where the applicant has no valid management system certificate, including where it has been suspended or annulled, the applicant adopts a decision to terminate the declaration of conformity and files a notification with the body that registered it. The corresponding entry is made in the single register.

One declaration for several regulations

Paragraph 106 of the standard schemes dispels a common misconception that every regulation needs its own document: “Where two or more technical regulations apply to the same products and the technical regulations establish the same form of conformity confirmation for such products (declaration of conformity), one declaration of conformity is drawn up in respect of such products, specifying the technical regulations with whose requirements the products comply.”

The condition is strict — the same form of confirmation. If one regulation requires declaration and another certification, they cannot be combined into a single document.

Two systems of schemes operating at the same time

Two systems of standard conformity assessment schemes run in parallel in the EAEU today, and which applies depends not on the product but on the date the technical regulation was adopted. This is one of the most overlooked details of the whole structure, and it is written into the text of the decision.

Sub-paragraph (b) of paragraph 2 of Decision of the Council of the EEC of 18 April 2018 No. 44 provides, word for word: “The Regulation on the procedure for applying standard schemes for assessing (confirming) conformity with the requirements of the technical regulations of the Customs Union, approved by Decision of the Customs Union Commission of 7 April 2011 No. 621, applies to conformity assessment of objects of technical regulation against the requirements of technical regulations of the Eurasian Economic Union (Customs Union) adopted before the date this Decision enters into force, to the extent not inconsistent with the provisions established in those technical regulations …, until amendments are made to them concerning the establishment of forms, schemes and procedures of conformity assessment based on the standard conformity assessment schemes approved by this Decision.”

How this works out

In practice, then: The great majority of regulations in force — 35 of the 48 — are TR CU instruments of the 2011 to 2014 series, adopted long before 2018. The count is direct: the register of regulations in force holds 35 entries designated “TR CU” and 13 designated “TR EAEU”. For those the schemes carry different names and different numbering from “1d to 6d”. Labels such as “scheme 3d” applied to TR CU 004/2011 or TR CU 021/2011 are correct only to the extent that the regulation itself has been brought across to the new schemes.

Decision No. 621 itself remains in force. It entered into force on 13 May 2011, and its only modification came through Decision No. 44 in 2018. It has not been repealed; its scope has been narrowed.

Two further blocks inside Decision No. 44

Besides the standard schemes, Decision No. 44 approved two additional documents whose existence is often forgotten.

Temporary measures applied in the certification of serially produced goods in an unfavourable epidemiological situation associated with the spread of coronavirus infection. These measures were limited by the calendar: paragraph 3.2 of Decision No. 44 provides that “the temporary measures operate for 24 months from the date of entry into force of Decision of the Council of the Eurasian Economic Commission of 23 December 2020 No. 127”. That period has expired, and the temporary measures can no longer be cited as an operative mechanism.

A temporary procedure for confirming compliance with the requirements of Union technical regulations for electronic commerce goods, together with a form of statement of safety for an electronic commerce good. This block was introduced by Decision of the Council of the EEC of 15 July 2022 No. 107, and the relevant paragraphs entered into force on 1 January 2023. For cross-border e-commerce this is a distinct regime and should not be mixed up with ordinary declaration of conformity.

Why this matters to the budget

Choosing the wrong system of schemes costs time rather than a fine. A conformity confirmation body that receives an application citing a scheme which does not exist in the applicable regulation will return the document set. Sub-paragraph (c) of paragraph 12 of the Procedure for registering declarations expressly makes it a free-standing ground for refusal that there is “no requirement in the technical regulation establishing that conformity of a particular type of product with the requirements of the technical regulation is confirmed in the form of adopting a declaration of conformity”.

The right order of work is: open the text of the applicable regulation, read its conformity assessment section, and only then talk about schemes. The regulation is the only source that knows which scheme applies to your product.

The evidence file: what exactly you have to assemble

A declaration of conformity is an assertion by the applicant, and the evidence file is what supports it. Its contents are set by the technical regulation, and where the regulation is silent, by paragraph 26 of the standard schemes.The file differs for serial output and for a batch, and the difference is substantive.

The file for serially produced goods

Sub-paragraph (a) of paragraph 26 of the standard schemes lists:

•          a copy of the technical documentation — design, and (or) technological, and (or) operational documentation, and (or) technical conditions (descriptions) for the product, setting out the main parameters and characteristics of the product together with its description;

•          a list of standards from the list of standards, giving designations and titles and, where compliance with the regulation is achieved by applying particular sections, paragraphs or sub-paragraphs rather than the standard as a whole, identifying those — where the applicant has applied them;

•          a description of the technical solutions adopted and of the results of risk assessment, where standards from the list are absent or were not applied;

•          the contract with the manufacturer, including a foreign manufacturer, providing for assurance of conformity and liability for non-conformity — for a person authorised by the manufacturer, in the cases provided for by the scheme;

•          a management system certificate — in the cases provided for by the scheme (that is, under scheme 6d);

•          information on the applicant’s registration or accounting number assigned on state registration;

•          reports of research (testing) and measurement of product samples — where available;

•          other documents at the applicant’s choice.

The file for a batch or a single article

Sub-paragraph (b) of paragraph 26 is shorter and is built around identifying the particular consignment:

•          a copy of the contract (supply agreement) and the shipping documents identifying the batch of products or the single article, including the size of the batch;

•          a copy of the operational documents — where necessary;

•          the list of standards applied from the list of standards;

•          information on the applicant’s registration or accounting number;

•          reports of research (testing) and measurement — where available;

•          other documents at the applicant’s choice.

The translation rule

Paragraph 27 of the standard schemes settles the language question: “Documents referred to in paragraph 26 of this instrument drawn up in a foreign language shall be accompanied by a translation into Russian and (or), where the legislation of the member state so requires, into the state language of the member state in which the declaration of conformity is registered.”

For Kazakhstan that means the technical documentation of a European or Chinese plant must arrive with a translation. The provision does not require notarial certification of the translation — it requires the translation.

Additional requirements in the Kazakh Rules

The national Rules on conformity assessment, approved by order of the acting Minister of Trade and Integration of the Republic of Kazakhstan of 29 June 2021 No. 433-NQ, add two blocks to the application that the Union list does not contain. Paragraph 71 of the Rules requires, in addition to the evidence file:

•          documents confirming the stability of production of the goods;

•          documents confirming the technical competence of the manufacturer’s own testing laboratories — accreditation certificates or equivalent documents and information — or a contract with accredited laboratoriesfor the testing required by the production process and by the regulations.

The second item repays a second reading. If an applicant relies on the manufacturer’s own laboratory — which schemes 1d and 2d permit — it must document that laboratory’s technical competence. “We tested it in-house”, without such documentation, does not satisfy the requirements for the document set.

The tightening of September 2025

By order of the Minister of Trade and Integration of the Republic of Kazakhstan of 15 September 2025 No. 263-NQ, paragraph 70 of the Rules was amended to refine what counts as evidence. The provision now expressly treats as evidence the technical documentation — project, design, technological and operational — and other documentation directly or indirectly confirming the conformity of the product, the results of the applicant’s own research and measurement, and other documents.

The purpose of the amendment is clear in the context of the campaign against documents issued without real testing: the regulator is widening what a conformity confirmation body must see before registering a declaration.

The management system certificate as evidence

Paragraph 70 of the Rules contains a limitation that is often ignored: a quality management system certificate of conformity may be used as part of the evidence when adopting a declaration of conformity, except where the technical regulations provide a different form of conformity confirmation for the product. An ISO 9001 certificate strengthens the file, but it does not replace a mandatory procedure where the regulation requires product certification.

Registering a declaration under an EAEU technical regulation: three working days

A declaration of conformity with a Union technical regulation takes effect not on signature but when a registration number is assigned to it in the single register. The procedure is set by Decision of the Board of the Eurasian Economic Commission of 20 March 2018 No. 41, which entered into force on 1 July 2018.

That decision repealed its predecessor, Decision of the Board of the EEC of 9 April 2013 No. 76 approving the Regulation on registration of declarations of conformity with the requirements of the technical regulations of the Customs Union. Paragraph 2 of Decision No. 41 preserved declarations registered earlier: they are valid until the end of their validity period.

The current version reflects the amendments made by Decision of the Board of the EEC of 20 December 2022 No. 200.

Who registers

Paragraph 3 of the Procedure: registration is carried out by bodies (organisations) of the member states authorised to do so, including accredited certification bodies of the member states which are included in the single register of Union conformity assessment bodies and whose scope of accreditation covers the products being declared, where the legislation of the member states so provides.

The qualification “where the legislation of the member states so provides” is the source of differences between Union countries. In Kazakhstan it is the conformity confirmation body that registers the declaration: paragraph 3 of Article 34 of Law 396-VI provides that a declaration is subject to registration in the technical regulation register or in the EAEU single registers by the conformity confirmation body whose scope of accreditation includes that type of product. Self-registration by the applicant through a state service, as some jurisdictions have arranged it, does not exist in Kazakhstan.

How documents are filed

Paragraph 4 of the Procedure permits two forms of filing: as electronic documents over the internet, or as paper documents — in person, by courier or by registered post with a list of enclosures and acknowledgement of receipt, unless the legislation of the member state provides otherwise.

Where filing is electronic, the declaration and the application are signed with an electronic digital signature obtained by the applicant under the legislation of the member state, and the accompanying documents are submitted electronically (paragraph 6).

What is attached to the declaration

Paragraph 5 of the Procedure lists four blocks:

(a) An application for registration containing full particulars of the applicant and the manufacturer, the name and designation of the products, identification information, the designation of the document to which the products were made, the EAEU HS code or codes, the name of the object of declaration and the names of the applicable technical regulations. The 2022 version added two new fields to the application: the storage conditions and storage period of the productand the service life (shelf life) or resource of the product — in the cases provided for by regulations, normative documents, standardisation documents and the manufacturer’s technical documentation.

(b) Information confirming the state registration of the legal entity or individual entrepreneur.

(c) A copy of the contract with the manufacturer — for a person authorised by the manufacturer, bearing the applicant’s seal and signature.

(d) Copies of the evidentiary materials whose submission the regulation requires, including the results of research (testing) and measurement.

Three working days and five grounds for refusal

Paragraph 8 of the Procedure: the body registers the declaration by assigning it a registration number, or notifies the applicant of refusal stating the reasons, within a period not exceeding three working days from receipt of the declaration of conformity, unless the technical regulation provides otherwise.

The list of grounds for refusal is closed — paragraph 12 of the Procedure:

The fourth ground is the one discussed in the previous section. The body must check the range of applicants against the object of declaration — series, batch or single article.

A registered declaration cannot be amended

Paragraph 14 of the Procedure puts it in one sentence: “Amendments may not be made to a registered declaration of conformity. Where amendments are necessary the applicant adopts a new declaration of conformity and registers it in accordance with this Procedure.”

This is no small matter: any typographical error in the product name, the address or the HS code requires a new document rather than a correction of the old one. The only mitigation is the replacement mechanism discussed below.

Payment

Paragraph 13 of the Procedure: “The need to pay for registration of a declaration of conformity and, where such payment is established, the procedure for it are determined by the legislation of the member states.” The Union levies no charge of its own and hands the question to national law.

Kazakhstan’s national declaration: five working days and a digital system

A national declaration of conformity of the Republic of Kazakhstan is governed by different rules from a declaration under an EAEU technical regulation, and the two should not be conflated. The national procedure is set out in the Rules on conformity assessment approved by order of the acting Minister of Trade and Integration of the Republic of Kazakhstan of 29 June 2021 No. 433-NQ.

The order was registered with the Ministry of Justice on 8 July 2021 under No. 23364 and brought into operation on 1 July 2021 — a week before its own registration with the Ministry of Justice. This does happen, and it is not a flaw in the instrument: the operative date is fixed by the order itself, while registration confirms its normative character.

The chain of amendments to the Rules

Order No. 155-NQ of 2026 is the most consequential of these: it rewrote the key paragraphs on registration and retention and completed the move of the procedure into digital form.

How the application is filed

Paragraph 71 of the Rules: to register a declaration of conformity the applicant submits an application for registration of a declaration of conformity to the conformity confirmation body through the digital technical regulation system. The national procedure offers no paper alternative.

The application includes, among other things:

•          the applicant’s full name, registered address and the addresses of its places of business, business identification number (BIN) or individual identification number (IIN), telephone number and email address;

•          the manufacturer’s full name and the addresses of the places where the products are made;

•          the name and designation of the products and information allowing them to be identified;

•          the designation and title of the document to which the products were made — the technical regulation and (or) a standardisation document;

•          the product’s EAEU HS code or codes and the product identification code assigned in the National Catalogue of Goods;

•          the name of the object of declaration: for a series, the entry “serial output”; for a batch, the size of the batch and the production period; for a single article, the serial number and date of production; for a batch and a single article, the particulars of the shipping documentation;

•          the name of the technical regulation or standardisation document.

Note the requirement for a product identification code in the National Catalogue of Goods — a new field with no Union equivalent, examined separately in the next section.

Five working days and only two grounds for refusal

Paragraph 73 of the Rules as amended by order No. 155-NQ, in force from 12 July 2026: the conformity confirmation body registers the declaration of conformity in the technical regulation register through the digital technical regulation system, or notifies the applicant of refusal of registration stating the reasons, within a period not exceeding five working days from receipt of the declaration of conformity. The declaration or the refusal notice is sent to the applicant through the same digital system.

Paragraph 74 gives a closed list of two grounds for refusal:

•          submission otherwise than in full of the documents and information required by paragraph 71 of the Rules;

•          failure of the applicant which adopted the declaration to meet the requirements of the Law.

The national list of grounds is shorter than the Union one, which has five. That is not a contradiction: they are different documents for different objects of regulation.

The validity of a national declaration

Paragraph 75 of the Rules as amended by order No. 124-NQ of 30 March 2023: “A declaration of conformity is adopted for the period established by the manufacturing enterprise (or the provider of the works or services) on the basis of the planned period of output of the product in question.”

The Rules set no ceiling — neither a year nor five years. That distinguishes the national declaration from the Union one, where paragraph 112 of the standard schemes caps validity at five years. Claims of a “maximum of one year” that circulate among commercial intermediaries are not supported by the text of the Rules.

Electronic form only

Paragraph 76: “A declaration of conformity is drawn up in electronic form and signed with an electronic digital signature.” The current version of the Rules provides for no paper form of the national declaration.

That is consistent with the regulator’s own account: at the briefing of 10 July 2026 Bauyrzhan Kasymov said that “the process of drawing up all documents has been fully transferred into the e-KTRM information system”.

When a new declaration is required

Paragraph 81 of the Rules: where the requirements of the technical regulations and standardisation documents named in the declaration change, and also where the applicant’s legal form or form of ownership, address or contact details change, the applicant draws up a new declaration of conformity.

The list is broader than it first appears: a change of registered office, or even of contact details, formally requires a new national declaration. The national Rules do not expressly describe a mechanism of “replacement without repeat procedures” equivalent to paragraph 114 of the Union standard schemes.

Building an internal process so that an office move or a change of legal form does not leave products without a valid document is a management task rather than a technical one, and it is usually solved alongside the company’s accounting and legal support. That kind of support is what UPPERSETUP’s accounting service provides.

The National Catalogue of Goods: a new mandatory field

Since 2025 an application to register a declaration of conformity in Kazakhstan must contain the product identification code assigned in the National Catalogue of Goods. This requirement is written into paragraph 71 of the Rules on conformity assessment and sits alongside the EAEU HS code.

The Rules for maintaining the National Catalogue of Goods and for registering goods in it were approved by order of the Minister of Trade and Integration of the Republic of Kazakhstan of 31 July 2025 No. 232-NQ, registered with the Ministry of Justice on 31 July 2025 under No. 36544 and brought into operation ten calendar days after first official publication. The legal basis is sub-paragraph 15-12) of Article 7 of the Law of the Republic of Kazakhstan “On the regulation of trading activity”.

In their first year the Rules were rewritten twice: they now stand as recast by order of the Minister of Trade and Integration of 2 October 2025 No. 284-NQ, in operation from 1 January 2026, with paragraphs 2, 3, 4, 7, 11 and 14 further amended by order of the acting Minister of 31 March 2026 No. 153-NQ, in operation from 12 July 2026— the same day as the new version of the Rules on conformity assessment.

Two operators, not one

Paragraph 7 of the Rules splits the roles between two different organisations, and confusing them is a common error in accounts of the catalogue.

The single operator in the field of state procurement ensures the uninterrupted functioning of the National Catalogue of Goods. The catalogue is maintained in digital form, in Kazakh and Russian, and against the general classifier of goods, works and services.

The single operator for the marking and traceability of goods — a state enterprise, joint-stock company or partnership more than fifty per cent of whose voting shares belong directly or indirectly to the state — develops, administers and supports the digital marking and traceability system, including maintaining and updating the catalogue itself. It is this operator that moderates applications and assigns the identification code.

What information is registered

Paragraph 8 of the Rules lists five blocks:

•          general information about the product — name, classification, trademark, country of origin, manufacturer;

•          measurable parameters — linear dimensions, mass, composition;

•          details of the standardisation documents to which the product was made;

•          conformity assessment documents for goods subject to mandatory conformity assessment (for goods already in trade circulation);

•          graphic material illustrating the product’s appearance.

The fourth item looks circular: an application for a declaration requires a catalogue code, while a catalogue entry requires a conformity assessment document. There is no circularity — the qualification “for goods already in trade circulation” confines the requirement to goods already on the market.

How a product is registered

Paragraph 14 of the Rules, in the version in force from 12 July 2026: registration is carried out on the National Catalogue of Goods internet resource or through the trading entity’s own digital system integrated with the catalogue. Paragraph 15: a product is subject to registration if no information about it is held in the catalogue.

Before registering goods, the trading entity registers itself by submitting information signed with the electronic digital signature of the chief executive of the legal entity or of the individual entrepreneur: the IIN or BIN (or, where a non-resident has neither, the tax registration number in the country of incorporation), the name, the chief executive’s name, an email address, a contact telephone number and the type of entity.

A separate provision of paragraph 16 deals with foreign manufacturers: they are registered in the catalogue on the applications of Kazakh individuals or legal entities holding a notarised power of attorney from the foreign manufacturer for its registration. The logic is the same as in conformity confirmation: the foreign person acts through a resident.

Paragraph 18 offers two ways to register a product: a standard application and a template file for bulk upload. With a standard application the entity selects the category from the general classifier, fills in the mandatory information and runs a preliminary check of the application using artificial intelligence built into the system.

Time limits and refusal

Paragraph 20 of the Rules sets the moderation periods for the single operator for marking and traceability:

•          3 working days from filing — for use of the goods in trade;

•          10 working days — for use of the goods in regulated state procurement.

Paragraph 21 gives two grounds for refusal: the product is already registered in the catalogue, or the information supplied is incomplete or unreliable. On the second ground the operator states which requirements the information fails, and allows the same three working days for trade and ten working days for state procurement to put it right (paragraph 22).

Where no ground for refusal exists, the application is published with a unified name and a product identification code assigned — the very code that then goes into the application to register a declaration of conformity.

A refusal is appealable under Article 91 of the Administrative Procedural Code of the Republic of Kazakhstan (paragraph 23).

What this changes in the sequence of steps

A mandatory intermediate step has appeared between identifying the applicable technical regulation and filing the declaration application:

1.        Identify the applicable technical regulation and the form of conformity confirmation.

2.        Determine the EAEU HS code.

3.        Register the trading entity, then the product, in the National Catalogue of Goods and obtain the identification code.

4.        Carry out testing and assemble the evidence file.

5.        File the application with the conformity confirmation body in the digital technical regulation system.

Skipping the third step leaves the application incomplete — and incompleteness of the file under paragraph 71 is one of the two grounds for refusal of registration under paragraph 74 of the Rules on conformity assessment.

The catalogue forms part of a wider traceability system: electronic invoices, the Virtual Warehouse module, marking with means of identification and accompanying waybills. The product data given when declaring conformity must reconcile with the data in the tax and customs systems. How that side of the record-keeping works is examined in E-invoices and the Virtual Warehouse in Kazakhstan.

How long a document lasts and what happens to stock afterwards

Goods released into circulation while a declaration or certificate was valid remain lawful for their whole shelf life or service life — even after the document has expired. This is one of the most useful and least known provisions in Union law, and it is recent.

The paragraph inserted into paragraph 5 of the Protocol on technical regulation by the Protocol of 31 March 2022 (in force from 12 February 2024) reads: “Documents confirming the conformity of products with the requirements of the technical regulations of the Union are valid in respect of each unit of product released into circulation during the period of validity of the document confirming the conformity of products with the requirements of the technical regulations of the Union, for the duration of the shelf life or service life of the product.”

What follows from it

Take an example. A company registers a declaration for serial output valid for five years, from 1 March 2022 to 28 February 2027. A batch is manufactured and shipped from the warehouse on 10 February 2027, and the product’s shelf life is 24 months.

That batch remains lawful until February 2029, even though the declaration expired in February 2027. Neither re-issuing a document for goods already released nor withdrawing them from shelves is required.

A batch manufactured on 5 March 2027, by contrast, needs a new valid document: it was not released into circulation while the earlier declaration was in force.

The practical consequence for retail and distribution: the expiry of a declaration does not make warehouse stock unlawful. It closes off the release of new units.

A declaration for serial output reaches backwards

There is a symmetrical rule working into the past. Paragraph 109 of the standard schemes: “A registered declaration of conformity for serially produced goods which are an object of technical regulation of a technical regulation extends to those goods manufactured from the date of manufacture of the selected samples of products which underwent research (testing) and measurement.”

So the declaration covers not only goods produced after its registration but everything manufactured from the date those tested samples were made. The relevant information and the date of manufacture of the samples may be given in field 8, “additional information”, of the single form of declaration.

The provision saves money in a familiar situation: production is running, batches are accumulating in the warehouse, and the declaration procedure takes several weeks. If the tested samples come from an early batch, all subsequent output is covered retrospectively. The retrospective effect arises from the first sentence of paragraph 109 and is not conditional on the field 8 entry — but recording the date of manufacture of the samples there is worth doing: it is the only way to show an inspector from what point the cover runs.

Maximum validity periods

The qualification “unless the technical regulation provides otherwise” applies to both rows of the Union column. Individual regulations set their own maximum periods, and those prevail over the general five-year rule.

The wording “for a batch of products no validity period of the declaration of conformity is set” means exactly that: a batch declaration does not expire. It is tied not to the calendar but to a specific quantity of goods identified by the shipping documents.

The date a document takes effect

Paragraph 117 of the standard schemes: “A declaration of conformity is treated as registered from the date a registration number is assigned to it in the single register of issued certificates and registered declarations of conformity.” For a certificate the corresponding rule reads the same way: the start date of a product certificate of conformity is the date of its registration in the single register.

The applicant’s signature, the date on the form and the date of the contract with the conformity confirmation body have no legal bearing on when the document takes effect. Only the register entry does.

The EAC mark: what it means, how it looks and where it goes

The single mark of product circulation on the market of the Eurasian Economic Union is mandatory marking, not a decorative element of packaging. Only a person whose products have passed every conformity assessment procedure required by the applicable regulation is entitled to apply it.

The rules are set by Decision of the Customs Union Commission of 15 July 2011 No. 711, in force since 2 September 2011. As with the Unified List, the current title differs from the original: the instrument is now called “On the single mark of product circulation on the market of the Eurasian Economic Union and the procedure for its application”. The renaming came through Decision of the Council of the EEC of 17 March 2016 No. 22, whose version has applied since 29 May 2016. Before that the title referred to “the market of the member states of the Customs Union”.

The decision has been amended three times in all: by Decision of the CU Commission of 23 September 2011 No. 800 and Decisions of the Council of the EEC of 20 July 2012 No. 61 and 17 March 2016 No. 22.

What the three letters mean

Paragraph 3.2 of the Procedure describes the image: “a combination of three stylised letters ‘E’, ‘A’ and ‘C’, executed graphically with right angles, having identical height and width, forming the exact proportions of a square”. The same paragraph expands the abbreviation: EAC stands for Eurasian Conformity.

Technical requirements for the mark

Paragraph 5.1 is the provision most often misread. The conjunction “or” in it is disjunctive: the mark is applied to each unit of product, OR to the packaging, OR to the accompanying documentation. The general rule does not require it on all three carriers at once — but a particular technical regulation may impose a stricter rule, and paragraph 5.3 refers expressly to it.

Who may apply the mark

Section 4 of the Procedure: manufacturers, persons authorised by the manufacturer and importers (suppliers) of products have the right to mark them with the single mark of circulation if the products have passed all the conformity assessment procedures established by the relevant technical regulation on the territory of any of the member states of the Eurasian Economic Union, as confirmed by the documents provided for the relevant forms of conformity assessment.

The phrase “on the territory of any of the member states” is the basis of mutual recognition: a declaration registered in Armenia gives the right to mark goods for sale in Kazakhstan.

The prohibition on misleading marking

Paragraph 5.4: “Marking, marks and inscriptions capable of misleading consumers and interested persons as to the meaning and image of the single mark of circulation (EAC) are not permitted.”

Practice knows two typical breaches of this paragraph. The first is applying the EAC mark to products that have been through no conformity assessment procedures. The second is the use of graphically similar signs which are not the EAC mark but are read as it.

The language of marking

Paragraph 6 of the Protocol on technical regulation requires that where products circulate on the territory of the Union the marking must be applied in Russian, and where the legislation of a member state so requires, in the state language of the member state on whose territory the products are sold.

For Kazakhstan that means bilingual marking: Russian by force of the Protocol, Kazakh by force of national legislation on languages and consumer protection. Imports marked only in English or Chinese are a breach an inspector can see without any expert examination.

The national conformity mark is a separate story

Kazakhstan has its own conformity mark, distinct from the EAC mark. Article 33 of Law 396-VI: the conformity mark is intended for marking products that have passed conformity confirmation procedures; its image, the technical requirements for it and the marking procedure are determined by national standards. Paragraph 4 of the same Article imposes a prohibition: the conformity mark may not be applied to products subject to mandatory conformity confirmation which have not passed confirmation of conformity with the requirements established by technical regulations and (or) national standards.

The registers: checking a document in two minutes

A conformity assessment document about which the register holds no information may not be used in Kazakhstan.That is not advice but an express prohibition, repeated twice in the statute.

Paragraph 4 of Article 17 of Law 396-VI: “The use on the territory of the Republic of Kazakhstan, when releasing into circulation products subject to mandatory conformity confirmation, of certificates of conformity about which no information is held in the technical regulation register or in the single registers of issued or adopted conformity assessment documents of the Eurasian Economic Union, is not permitted.” Paragraph 9 of the same Article repeats the rule for declarations of conformity.

Paragraph 2 of Article 35 reinforces it: “The release into circulation of products covered by technical regulations that have been brought into operation is prohibited where those products have not undergone conformity assessment, and also where they are released without conformity assessment documents or where no information about such documents is held in the technical regulation register or in the single registers.” The same provision bans advertising such products.

Where to look

Paragraph 5 of the Protocol on technical regulation: “The single registers of issued or adopted conformity assessment documents are placed on the official website of the Union on the internet.” The procedure for forming and maintaining them was approved by Decision of the Board of the EEC of 26 September 2017 No. 127, in force from 27 March 2018, as amended by Decision of the Board of the EEC of 4 April 2023 No. 46 (that version applying from 6 May 2023). Paragraph 15 of the Procedure states the status of the data plainly: “The information contained in the single register is open and publicly available.” Paragraph 14 allows a QR code to be placed in the national part of the register for quick access to the electronic record of a document — whether to place it is for the member state’s authorised body to decide.

The state of the Union register as at 16 September 2026. The register page address published by the Eurasian Economic Commission itself in its index of databases opens, but instead of a search form it shows the notice “The resource is being updated”. That is no reason to treat the register as inoperative — the national parts are maintained by the member states and are accessible through national systems — but checking a document registered in another Union state may mean going to the national register of the state of registration.

What is publicly available in Kazakhstan

The public part of the digital technical regulation system holds separate registers for each type of document. Checked on 16 September 2026, the following open without authorisation, among others: the register of declarations of conformity, the register of certificates of conformity for products of the Republic of Kazakhstan, the register of declarations of general safety, the register of test reports, the register of accredited bodies and the register of certificates assigning an international manufacturer identification code to vehicle makers.

The register of declarations shows, for each entry: the application number, the date of creation, the applicant’s BIN, the applicant’s name, the BIN of the conformity confirmation body, the body’s name, the type of application, the declaration scheme, the object of declaration and the status.

Matching the applicant’s BIN in the register against your counterparty’s BIN is the first and fastest check. The second most important parameter is the object of declaration: “serial output” or a specific batch. A batch declaration does not cover the next consignment of the same goods.

The “Technical regulations of the RK” section of the digital system requires authorisation, so the full list of national regulations in force cannot be checked publicly. Verified on 16 September 2026.

The legal basis of the register

Article 18 of Law 396-VI describes how the technical regulation register is compiled: from data held by state bodies in the field of permits and notifications, by individuals and legal entities, by central and local executive bodies, by the State Corporation “Government for Citizens”, and also from the single registers of issued or adopted conformity assessment documents of the Eurasian Economic Union. Access to the register’s data is through the web portal of the authorised body.

The word “digital” in the system’s name is itself recent. By the Law of the Republic of Kazakhstan of 9 January 2026 No. 256-VIII, throughout the text of Law 396-VI the words “information system” were replaced by “digital system”; the amendment is brought into operation six months after first official publication. The date of the latest amendment to the Law in the Adilet legal information system is 12 July 2026.

What a failed check looks like

The regulator gave a concrete example at the briefing of 19 May 2026. In Shymkent, on an attempt to import chocolate glaze from Germany, specialists found a declaration of conformity issued in Kyrgyzstan but absent from the EAEU single register. After checking, the document’s validity was terminated.

A document on the official form, with a signature and a seal and a well-formed number — and no register entry. Legally that document does not exist, and the goods count as released into circulation without conformity assessment, with everything that follows under Article 415 of the Administrative Offences Code.

Evidence retention: where Union law and the Kazakh statute diverge

Union law requires the evidence file to be kept for ten years; the Kazakh statute says three. This is a genuine divergence rather than a mere difference of interpretation, and it resolves in favour of the longer period.

What Union law says

Paragraph 123 of the standard conformity assessment schemes approved by Decision of the Council of the EEC No. 44: “Where the technical regulation does not establish a period for the applicant to retain the declaration of conformity and the evidence file, that period is 10 years from the date of its registration.”

The same paragraph deals with the case of several regulations: “Where several technical regulations apply to the products and establish different periods for the applicant to retain the declaration of conformity and the evidence file, the longest of the established retention periods applies.”

For the body that registered the declaration, the same paragraph provides that retention requirements for copies are determined by the legislation of the member states, and the retention period for such copies is no less than 5 years from the expiry of the declaration of conformity, or, where the declaration has no fixed validity period, no less than 10 years from the date of its registration.

Paragraph 16 of the Procedure for registering declarations approved by Decision of the Board of the EEC No. 41 repeats this rule for the application and the copy of the registered declaration.

What the Kazakh statute says

Paragraph 5 of Article 34 of Law 396-VI: “For three years from the expiry of the validity of the declaration of conformity, the first copy of the declaration of conformity and the materials used as evidence for confirming conformity are kept by the applicant, and the second copy of the declaration of conformity is kept by the conformity confirmation body which registered it.”

Paragraph 77 of the Rules on conformity assessment, as amended by order No. 155-NQ and in force from 12 July 2026, recasts this for the digital system: “For 3 (three) years from the day the validity of the declaration of conformity expires, the declaration of conformity and the materials used as evidence for confirming conformity are kept in the digital technical regulation system on a permanent basis.”

Comparison and the practical conclusion

The divergence is resolved by paragraph 2 of Article 2 of the Kazakh Law itself: “If an international treaty ratified by the Republic of Kazakhstan establishes rules other than those contained in this Law, the rules of the international treaty apply.” The standard schemes were approved by a decision of an EAEU body in implementation of the Protocol, which is an annex to the Treaty on the Union.

The practical conclusion is straightforward: for declarations under EAEU technical regulations, work to the ten-year period. Retaining beyond the national minimum means two or three extra years and some server space; missing evidence on inspection means cancellation of the document and a fine.

For national declarations of the Republic of Kazakhstan the three-year period applies on its own terms — Union law does not touch the question there.

What exactly is retained

The evidence file for a declaration is described in paragraph 120 of the standard schemes, and should not be confused with paragraph 26, which lists the documents serving as the basis for adopting the declaration. The paragraph 120 file comprises: a copy of the technical documentation; the list of standards applied from the list of standards; the description of the technical solutions adopted and of the risk assessment results; reports of research (testing) and measurement; copies of the contract and shipping documents and a copy of the contract with the manufacturer — in the cases provided for by the declaration scheme; a copy of the management system certificate — in the same cases; information on the applicant’s registration number; other documents at the applicant’s choice; a product type certificate — in the cases provided for by the scheme; and the registered declaration of conformity itself.

For certification the file is wider and is set out in paragraph 119 of the standard schemes: it additionally includes the identification and (or) sampling report or reports, and, where the technical regulation so provides, the corresponding photographic and (or) video material, certificates of conformity or declarations and (or) test reports for critical components, raw materials, materials, parts or component parts of the product, copies of the contract and shipping documents, the product design examination opinion in the cases provided for by the certification scheme, and the certificate of conformity for the product itself.

Paragraph 124 of the standard schemes adds a duty to produce the documents, and it differs between the two forms. In certification the paragraph 119 documents are produced by the applicant and (or) the product certification body on demand by the state control (supervision) bodies of the member states. Where conformity is declared, the paragraph 120 documents are produced by the applicant alone on demand by the same bodies. In both cases the documents are also produced to other interested persons where the legislation of the member states so provides.

Replacement, suspension and termination of a declaration

A registered declaration cannot be corrected — but in seven cases it can be replaced without repeat testing. The distinction between replacement, suspension and termination is fundamental: the first is initiated by the applicant without losing its market position, the second always comes from an inspector, and the third can come from either side.

Replacement without repeat procedures

Paragraph 114 of the standard schemes, as amended by Decision of the Council of the EEC of 25 January 2023 No. 11, lists the cases in which the applicant adopts a new declaration and registers it without carrying out the procedures provided for in sub-paragraphs (a) to (g) of paragraph 25 — that is, without choosing a scheme, analysing documents, sampling, production control, choosing a laboratory, testing or a type examination:

•          discovery of errors (typographical mistakes) in the declaration or its annexes;

•          a change in the legal form, location, address of the place of activity, telephone number and (or) email address — as regards the applicant;

•          a change in the legal form and location — as regards the manufacturer of the product;

•          renaming of a geographical object, a street, a planning-structure element, or a change in the numbering of the addressed object or the postal code in the address of the place of manufacture, provided the place of manufacture is in fact unchanged;

•          a change in the name of the legal entity or in the name of the individual entrepreneur while the registration number and the place of manufacture remain unchanged;

•          a change in the EAEU HS code or codes;

•          a reduction in the number of addresses of places where the products are manufactured.

The expiry date of the new declaration is the same as the expiry date of the declaration it replaces — replacement does not extend validity.

Field 8, “additional information”, of the new declaration carries the entry “adopted in replacement” with the registration number and registration date of the declaration being replaced (paragraph 115). On registering the new declaration the applicant adopts a decision to terminate the one being replaced (paragraph 116).

When replacement is not needed at all

The final paragraph of paragraph 114 contains a provision that saves time and money and that almost nobody knows about. Where a geographical object or street is renamed, numbering or the postal code changes, the applicant’s telephone number or email address changes, or the EAEU HS codes change — “replacement of the declaration of conformity and (or) its annexes is not required and is carried out at the applicant’s discretion”.

So a change of HS code is simultaneously listed as a ground for simplified replacement and treated as a case where replacement is optional. That is not a contradiction: the applicant may replace the document to keep its papers tidy, but is under no obligation to.

Suspension

Paragraph 18 of the Procedure for registering declarations: the ground for suspending a declaration of conformity registered in the national part of the single register is the issue to the applicant, by the state control (supervision) body of the relevant member state, of an enforcement notice suspending the declaration of conformity.

There are no other grounds. An applicant cannot suspend its own declaration — it can only terminate it.

Termination

Paragraph 19 of the Procedure names three grounds:

•          the applicant’s decision to terminate the declaration;

•          the issue to the applicant by the state control (supervision) body of an enforcement notice or the adoption by it of a decision to terminate the declaration;

•          the adoption by the state control (supervision) body of a decision declaring the declaration invalid.

Where the applicant takes the decision, it files with the body a notification of termination of the declaration by the applicant’s decision, bearing its seal and signature, stating the registration number, the date of registration and the reason for termination (paragraph 20). A notification filed electronically is signed with an electronic digital signature.

The body enters the termination date in the single register within a period not exceeding three working days from submission of the notification (paragraph 21). Where the information comes from a state control body, the body maintaining the national part of the register enters the date and registration number of the enforcement notice within three working days of receiving the information (paragraph 23).

The date from which everything happens

Paragraph 24 of the Procedure: “A declaration of conformity is treated as suspended, resumed or terminated from the date the corresponding information is entered in the single register.”

This mirrors the rule on when a document takes effect. Neither the date of the enforcement notice, nor the date the applicant was notified, nor the date of the supervisory body’s decision changes the document’s status by itself. Only the register entry does — which is precisely why checking a counterparty against the register should be a recurring exercise rather than a one-off at contract signature.

The self-destruct built into scheme 6d

A distinct case of termination is built into scheme 6d. Where the applicant has no valid management system certificate of conformity, including where it has been suspended or annulled, the applicant adopts a decision to terminate the declaration of conformity and files the corresponding notification. The entry is made in the single register by the body that registered the declaration.

A company that chose scheme 6d to save on testing takes on an obligation to maintain its management system certification without interruption. Suspension of an ISO certificate by the management system certification body automatically triggers termination of the product declaration.

State supervision: inspections, seizure and a ban on release into circulation

The Kazakh inspector has two instruments of immediate effect: a ban on releasing products into circulation, and seizure of products. Filing a complaint does not stop either. These are called prompt response measures — immediate enforcement powers in the Kazakh scheme — and are set out in Article 44 of Law 396-VI.

Article 44 applies as recast by the Law of the Republic of Kazakhstan of 6 April 2024 No. 71-VIII, brought into operation sixty calendar days after first official publication. The former version of the Article lapsed in its entirety — this is a new text, not a set of amendments.

When prompt response measures apply

Paragraph 1 of Article 44: the measures are applied by territorial subdivisions of the agency of the authorised body where products or activity are identified which present an immediate threat to the constitutional rights, freedoms and legitimate interests of individuals and (or) legal entities, to human life and health, to the environment or to the national security of the Republic of Kazakhstan.

Paragraph 3 names two kinds of measure: a ban on releasing products into circulation and seizure of products. There is no third.

The ground is a breach of requirements forming the subject of state control under Article 143 of the Entrepreneurial Code of the Republic of Kazakhstan (paragraph 4).

Procedure

The territorial subdivision draws up a supervisory instrument in the form of a ruling on the application of prompt response measures in the form approved by the authorised body (paragraph 5). The ruling is served on the person subject to control in accordance with Article 153 of the Entrepreneurial Code.

Paragraph 6 covers refusal to accept service: where service is in person and acceptance is refused, a corresponding note is made in the ruling and a video recording is made documenting the refusal. The ruling is then sent to the registered office, place of business or actual address by letter with acknowledgement of receipt.

Paragraph 7: “Refusal to accept a ruling on the application of prompt response measures is not a ground for failing to comply with it.”

A complaint does not suspend enforcement

Paragraph 13 of Article 44 confers a right of appeal: a subject of control which disagrees may file a complaint seeking to have the ruling declared invalid and set aside — with a superior state body under Chapter 29 of the Entrepreneurial Code, or with a court.

And immediately after that: “Filing a complaint does not suspend enforcement of the ruling on the application of prompt response measures.”

The grounds for declaring the ruling invalid are listed in paragraph 14 and number only three: absence of grounds for applying the measures; application of a measure on a ground that does not correspond to that measure; and application of measures on matters outside the territorial subdivision’s competence.

What happens to seized products

Paragraph 17 of Article 44: seized products which do not meet the requirements of technical regulations and present an immediate threat may not be used in economic or other activity and must be destroyed, or may be disposed of or recycled in compliance with the established requirements, or exported back outside the Republic of Kazakhstan.

Paragraph 18: “The costs associated with the carriage (transportation), storage, destruction, disposal or recycling of seized products, or with their export back outside the Republic of Kazakhstan, are borne by the person subject to control and supervision.”

That is the real price of a breach, and it usually exceeds the fine by a multiple.

Annulment of the conformity assessment document

Two paragraphs of Article 44 give the inspector the power to annul documents directly.

Paragraph 19: “Where laboratory testing of the products proves their non-conformity with the requirements of technical regulations, the conformity assessment document for the seized products is annulled by the officials of the territorial subdivision of the agency of the authorised body” who issued the seizure ruling.

Paragraph 20: “Conformity assessment documents for products which have not undergone conformity assessment in the established manner are annulled by the officials of the territorial subdivision of the agency of the authorised body carrying out state control and supervision.”

Paragraph 21: where forged conformity assessment documents are discovered, “the criminal prosecution bodies must be notified of this”.

What this looks like in figures

For the first half of 2026, on the figures given at the briefing by the acting chairman of the Committee for Technical Regulation and Metrology Bauyrzhan Kasymov at the Central Communications Service, the territorial agencies carried out more than seven thousand control measures:

Breaches were found in 4,267 cases (56% of the total). A total of 2,490 enforcement notices and recommendations were issued. Administrative fines of more than KZT 186 million were imposed. Twenty accreditation certificates were suspended and more than 42,000 conformity confirmation documents were annulled. Following state control, a ban on sale was imposed on 867 wholesale consignments of various products. More than 50 samples were acquired through test purchases.

Among the specific decisions of the same period: sale of Masima kettles was prohibited in East Kazakhstan Region, and of Defender and SMART surge protectors in Abai Region.

One further figure gives a sense of the scale of preventive work: more than 600 breaches were found in the field of uniformity of measurement — unverified scales, thermometers and blood-pressure devices.

The fines: what releasing goods without documents costs

Releasing products into circulation without conformity assessment documents, or where the register holds no information about them, costs a large enterprise 600 MCI — KZT 2,595,000 — and 1,200 MCI, or KZT 5,190,000, on a repeat offence within a year. Liability is set by Article 415 of the Code of the Republic of Kazakhstan on Administrative Offences of 5 July 2014 No. 235-V, in Chapter 24, “Administrative offences encroaching on public safety and public health”.

Article 415 applies as recast by the Law of the Republic of Kazakhstan of 5 October 2018 No. 184-VI (brought into operation six months after first official publication) as amended by the Law of the Republic of Kazakhstan of 10 January 2025 No. 155-VIII (brought into operation sixty calendar days after first official publication).

What is actually penalised

Part one of Article 415 describes two offences:

1) releasing into circulation products which do not meet the requirements established by technical regulations, and also the information stated in the conformity assessment documents;

2) releasing into circulation products covered by technical regulations that have been brought into operation where those products have not undergone conformity assessment, and also releasing them without conformity assessment documents or where no information about such documents is held in the technical regulation register or in the single registers of issued or adopted conformity assessment documents of the Eurasian Economic Union.

The second offence is the one a “grey” document falls under. The words “where there is no information about such documents in the register” make the paper itself legally irrelevant: only the register entry counts.

The amounts

The tenge figures are calculated on the monthly calculation index of KZT 4,325 set by paragraph 4 of Article 7 of the Law of the Republic of Kazakhstan “On the republican budget for 2026–2028” of 8 December 2025 No. 239-VIII from 1 January 2026.

Part two of Article 415 provides for the fine “with or without suspension of activity, and with or without confiscation of the products”. Confiscation and suspension are not automatic consequences but additional sanctions at the body’s discretion.

Note how the range of subjects is drafted: the Kazakh Code groups officials, small business entities and non-profit organisations together. There is no separate rate for an official here.

Article 415-1: liability of bodies and laboratories

Article 415-1 was inserted into Chapter 24 by the same Law of 5 October 2018 No. 184-VI and is addressed not to the seller but to the conformity confirmation infrastructure. It names six offences:

•          breach of the rules for carrying out conformity confirmation and (or) assessment procedures and verification of measuring instruments;

•          inaccuracy of test results when carrying out conformity confirmation and (or) assessment or verification of measuring instruments;

•          issuing documents confirming conformity, and issuing a certificate of verification of measuring instruments, without carrying out the mandatory procedures;

•          verification of measuring instruments and metrological attestation of measurement procedures by legal entities without accreditation;

•          use by accredited bodies of measurement standards which have not been calibrated or verified;

•          breach of the procedure for carrying out accreditation work.

The point of this Article is not the fine but the additional sanction. Part one provides for a fine “with suspension of the accreditation certificate and of the certificate of the expert auditor for conformity confirmation, and of the certificate of the verifier of measuring instruments, for a period of six months”. Part two, on a repeat offence within a year, provides for a fine “with withdrawal of the accreditation certificate and of the attestation of the expert auditor for conformity confirmation”.

For a customer of these services that is a direct counterparty risk: suspension of a conformity confirmation body’s accreditation certificate removes its ability to support documents already registered. In the first half of 2026, 20 accreditation certificates were suspended.

Article 416: failure to stop production when non-conformity is found

Article 416 penalises failure by the subject to stop carrying out product life-cycle processes from the moment non-conformity with the safety requirements is discovered, those requirements being established by the laws on the safety of food products, chemical products, machinery and equipment, and toys, and by technical regulations.

A note to the Article identifies the subjects: persons responsible for product safety under those laws.

For a large enterprise this is the most expensive Article in the Chapter: 1,600 MCI — KZT 6,920,000, with or without suspension of activity and with or without confiscation of the products. The duty to suspend output on discovering non-conformity is mirrored in sub-paragraph 7 of paragraph 2 of Article 31 of Law 396-VI, and the duty to ensure recall in sub-paragraph 8 of the same paragraph.

Civil liability alongside administrative liability

Paragraph 2 of Article 47 of Law 396-VI: harm caused to the life, health or property of an individual or to the property of a legal entity as a result of products failing to meet the requirements established by technical regulations is subject to compensation in accordance with civil legislation.

Paragraph 3 of the same Article extends liability to the infrastructure: where, as a result of a breach of conformity assessment procedures or their being knowingly inaccurate, non-conforming products subject to seizure have been released into circulation, the accredited body which issued (registered) the conformity assessment document, or which issued the test report that served as the basis for it, bears the liability established by the laws of the Republic of Kazakhstan.

For a company this means that a finding of breach can run on two tracks at once: the administrative track under Article 415 of the Administrative Offences Code, and the civil track on a claim by a consumer or counterparty. Challenging a ruling on prompt response measures, preparing representations and pursuing a recourse claim against the conformity confirmation body are matters for UPPERSETUP’s legal support.

“Grey” documents: what happened in 2025 and 2026

Kazakhstan has invalidated 1,113 certificates and declarations issued in EAEU states — 742 of them drawn up in Kyrgyzstan. This was not an episode but the result of a deliberate campaign that has changed the working conditions of the entire conformity confirmation market.

The figures were given on 19 May 2026 by the deputy chairman of the Committee for Technical Regulation and Metrology of the Ministry of Trade and Integration of the Republic of Kazakhstan, Bauyrzhan Kasymov. The source gives a total of 1,113 and a breakdown across three countries which sums to 997; the remaining 116 are not attributed by country.

What exactly was wrong

The regulator’s formulation leaves no room for interpretation: “In fact certain documents were issued without carrying out the necessary testing of products. In a number of cases they were drawn up remotely, without any real inspection of the goods. Such certificates made it possible to import products onto the Kazakh market unchecked for years.”

The inspections revealed more than formal defects in documents. In some food product samples, E. coli bacteria were found, as were excesses over the permitted levels of certain food additives. Some goods were being sold without the mandatory information on date of manufacture and storage conditions.

The response

The campaign produced three kinds of result, each of which changes practice.

A change in Kyrgyz legislation. In Bauyrzhan Kasymov’s words: “Together with our Kyrgyz colleagues we did serious work to put this area in order. Kyrgyzstan amended its legislation and transferred the function of registering declarations to a state organisation. That has substantially reduced the scope for issuing documents unlawfully.”

Withdrawal of accreditation. The Kyrgyz side annulled eight accreditation certificates of conformity confirmation bodies; those organisations were removed from the EAEU single register. Removal from the register means that any document such a body might issue in future has no force.

Blocking of websites. In Kazakhstan 76 websites have been blocked which offered to draw up certificates without going through the mandatory procedures.

Why this concerns a bona fide importer

It concerns him directly. The declaration does not lapse automatically: paragraph 19 of the EEC Procedure gives a closed list of grounds for termination, and withdrawal of the registering body’s accreditation is not among them, while paragraph 24 ties termination to the register entry. In practice, though, such documents are declared invalid by a decision of a state control body — which is exactly how the 1,113 documents were annulled. The outcome for the owner of the goods is the same: from the date of the register entry, the products on the shelf turn out to have been released into circulation without conformity assessment. Liability under Article 415 of the Administrative Offences Code attaches to whoever released the products into circulation, not to the body that issued the document.

That makes checking the conformity confirmation body itself as much a mandatory procedure as checking the document. Two things need checking: whether the body is included in the single register of Union conformity assessment bodiesand whether its scope of accreditation covers your products. Both checks are free and take minutes.

Signs that a document is worth re-checking

None of the signs below proves by itself that a document is invalid. But each is a reason to open the register before signing a contract.

The document was issued in a time physically incompatible with testing. Registration of a declaration takes three working days under Union law and five under the Kazakh Rules — but that is registration alone. Before it come identification, sampling and the testing itself, which in an accredited laboratory takes weeks. Paragraph 85 of the national Rules sets a ceiling of thirty calendar days for testing rather than a floor — but even a ceiling shows that the work is measured in weeks, not hours.

An offer to “arrange it without samples”. Schemes 3d, 4d and 6d require testing in an accredited laboratory. Identification and sampling are carried out under Section VI of the standard schemes where the declaration scheme so provides — and each of the three schemes named does provide for it alongside the documentary stages.

The applicant named in the document is not eligible to be one. If a declaration for serial output names an importer as applicant, the document was drawn up in breach of the range of applicants — a free-standing ground for refusal of registration under sub-paragraph (d) of paragraph 12 of the Procedure.

The body’s scope of accreditation does not cover the products. Paragraph 3 of Article 34 of Law 396-VI requires the declaration to be registered by a body whose scope of accreditation includes that type of product.

The document is not in the register. That is no longer a sign but a verdict: without a register entry the document may not be used, by paragraphs 4 and 9 of Article 17 of Law 396-VI.

Where the checks go next

According to the regulator, “all conformity assessment procedures have been digitised through the e-KTRM system, and the state revenue bodies have tightened the checking of documents during customs clearance of goods.”Reconciling a document against the register is moving out of the sphere of the importer’s voluntary diligence and into standard customs procedure.

For importers working with supplies from third countries this means a conformity assessment document is becoming as critical an element of the customs file as the contract and the invoice. Customs clearance and the obligations that go with it are examined in Importing into Kazakhstan from third countries, and VAT obligations on imports from Union states in VAT on imports from the EAEU into Kazakhstan.

The infrastructure: who accredits, who registers, who inspects

In Kazakhstan accreditation in the field of conformity assessment is classified as a state monopoly, carried out by a single republican state enterprise. That is an unusual arrangement even by the standards of neighbouring legal systems, and it is written into the statute.

The state monopoly

Article 9 of Law 396-VI is headed “State monopoly on accreditation in the field of conformity assessment”. Three activities fall within it:

•          accreditation in the field of conformity assessment;

•          forming, maintaining and supporting the technical regulation register;

•          monitoring compliance with good laboratory practice.

Paragraph 2 of the Article: those activities are carried out by a republican state enterprise established by decision of the Government of the Republic of Kazakhstan. Paragraph 3: prices for the goods, work and services of the state monopoly entity are set by the authorised body in agreement with the antimonopoly body.

That enterprise is the National Accreditation Centre, under the Committee for Technical Regulation and Metrology of the Ministry of Trade and Integration of the Republic of Kazakhstan. The legal form matters: the centre is a republican state enterprise on the right of economic management, not a limited liability partnership as it was in an earlier period. References to “NAC LLP” in 2026 are out of date.

The authorised body and its department

The authorised body in technical regulation is the central executive body exercising leadership and cross-sectoral coordination. Those functions sit with the Ministry of Trade and Integration of the Republic of Kazakhstan, and the agency that does the work is the Committee for Technical Regulation and Metrology, a republican state institution.

The distinction between ministry and committee is not a formality: secondary legislation on the rules of conformity assessment is issued by the minister, while the committee’s territorial agencies carry out control and apply prompt response measures.

Conformity confirmation bodies

Article 13 of Law 396-VI sets the framework for these bodies. They are subject to accreditation; in mandatory confirmation they must use the results of accredited laboratories; they work with applicants on a contractual basis and only within their scope of accreditation.

Two requirements from that Article deserve separate mention, because they address conflicts of interest head-on.

Paragraph 7: “Conformity confirmation bodies may not provide consulting services in the field of accreditation and must not be affiliated with persons providing such services.”

Paragraph 8: “Conformity confirmation bodies must own, or hold on another lawful basis, and use laboratories capable of testing objects of technical regulation.”

The bodies’ duties are listed in paragraph 5: to ensure applicants have unimpeded access to information on procedures and conditions; not to discriminate against applicants; to keep records of registered, issued, suspended and annulled (terminated) conformity assessment documents and of refusals of certification, and to transmit them; and to preserve the confidentiality of information constituting the commercial interest of applicants, irrespective of the country of origin of the products.

The scale of the infrastructure

As at July 2026, on the figures of the Committee for Technical Regulation and Metrology:

One practical conclusion follows from these numbers: 62 conformity confirmation bodies for the whole country is a competitive but manageable market. Checking a particular counterparty against the register of accredited bodies is not difficult, and it should be done before signing a contract rather than after a refusal of registration.

International recognition

A separate indicator matters to exporters: on calibration and measurement capability Kazakhstan ranks first among the countries of Central Asia and forty-fifth among the 112 participants in the CIPM MRA. Test reports from laboratories using the ILAC MRA combined mark are recognised outside the Union — a direct instrument for reducing the cost of entering export markets.

Recognition of foreign documents

Article 39 of Law 396-VI: certificates of conformity of foreign states, product test reports, conformity marks and other conformity assessment documents are recognised in the manner determined by the authorised body.

Paragraph 2 of the same Article contains an exclusion that participants in exhibitions and residents of special economic zones should know about: the provisions of the Article do not extend to foreign documents in respect of goods, works and services intended for post-exhibition use of the territory of an international specialised exhibition, or for the implementation of projects on the territory of special economic zones.

Separately, paragraph 6 of Article 25 of the Law allows foreign and international organisations issuing conformity assessment documents of a foreign type to operate in Kazakhstan on notifying the authorised body of the commencement of activity in the manner established by the Law “On permits and notifications”. The permits and notifications regime is examined in Permits and notifications in Kazakhstan.

What changed in 2024, 2025 and 2026

Over three years both the Union and the national tier were rewritten several times, and some of those changes took effect very recently — on 12 July 2026. The chronology below is not history but a checklist: for any procedure begun in the past you need to know which version was in force on the date the application was filed.

The central theme of the three years: full digitisation

Reduce all these changes to a single line and it is the move of conformity assessment into digital form — first at Union level, then nationally.

At Union level the Protocol of 31 March 2022 began it, adding to paragraph 5 of the Protocol on technical regulation the sentence: “Conformity assessment documents are drawn up in electronic form and (or) on paper in the manner approved by the Commission.” The construction “and (or)” leaves the paper form permissible.

Nationally Kazakhstan went further and effectively removed the paper form. Paragraph 76 of the Rules on conformity assessment: “A declaration of conformity is drawn up in electronic form and signed with an electronic digital signature.” Paragraph 71 requires the application to be filed in the digital technical regulation system. Paragraph 73, in the version in force from 12 July 2026, requires both registration and delivery of the result through the same system.

The regulator confirms this in its own words: at the briefing of 10 July 2026 it was stated that “the process of drawing up all documents has been fully transferred into the e-KTRM information system”.

What this changes in practice

Three consequences, each of which alters a project plan.

An electronic digital signature becomes a condition of entry. The national procedure requires an EDS obtained under Kazakh law. The Union Procedure is less demanding: paragraph 6 speaks of an EDS “obtained by the applicant in accordance with the legislation of the member state”, so a signature from any Union state will do. Sub-paragraph (e) of paragraph 12 nonetheless makes the absence of an EDS a self-standing ground for refusing registration.

The paper original ceases to be the carrier of the right. Legal significance attaches to the register entry. Demanding “the original with a seal” from a supplier is outdated practice; what needs checking is the register.

Product data must reconcile across several systems at once. The EAEU HS code, the identification code in the National Catalogue of Goods, the data in electronic invoices and in the customs declaration all describe the same product. A discrepancy between them is not a technical detail but a reason for questions from both the Committee and the state revenue bodies.

Adopted but not yet operative: what to expect in 2027 and 2028

Union law today contains a whole layer of instruments that have been adopted and published but are not yet operative. They should inform planning, but they cannot be applied. The distinction matters more here than in most subjects: a regulation entering into force in eighteen months confers no rights and imposes no duties today.

The Protocol of 28 July 2025: clarifications by the Commission

The Protocol amending the Treaty on the Eurasian Economic Union of 29 May 2014, signed in Moscow on 28 July 2025, had not entered into force as at September 2026.

For technical regulation it does one thing. Sub-paragraph 4 of Article 1 of the Protocol adds to paragraph 3 of the Protocol on technical regulation the sentence: “In order to ensure a uniform approach in the member states to the application of the provisions of the technical regulations of the Union, the Commission shall provide clarifications. The procedure for the Commission to provide such clarifications shall be determined by the Council of the Commission.”

The provision looks technical but addresses a real problem. Today different member states may read the same wording of a regulation differently, and there is no mechanism for an official clarification at Union level. Once the Protocol is in force and the Council of the Commission has approved the procedure, business will have an instrument that does not currently exist.

Until the Protocol enters into force, clarifications by the Commission cannot be cited as a binding source.

The calendar of entry into force

What a paint manufacturer should do today

The short answer: nothing mandatory yet. Until 1 January 2028 paint and varnish materials in Kazakhstan are governed by the Unified List or by national requirements, not by TR EAEU 053/2026.

Preparing early is nonetheless sensible, for three reasons.

First, the lead rule is deliberately stretched out in time. Under paragraph 2 of Decision No. 65 the limit on lead content calculated on dry residue under paragraph 12 of the regulation takes effect 60 months after the regulation enters into force, and not before the necessary interstate standards are added to the list of standards. For a transitional period of 36 months from entry into force an intermediate limit applies: no more than 0.5%. Reformulating over three years is realistic; over three months it is not.

Second, transitional provisions to regulations usually allow products released into circulation before entry into force to be sold on for some period. Planning warehouse stock against 1 January 2028 makes sense from 2027 onwards.

Third, the regulation was adopted at Kazakhstan’s initiative, as the regulator said expressly. That means the Kazakh industry took part in preparing it, and that national enforcement under this regulation will be active from day one.

Telling the adopted from the operative

A practical rule that removes most errors: every Council decision on a technical regulation carries at least three dates, and a decision adopting a regulation carries four.

Take TR EAEU 053/2026 as the example:

•          the date the decision was adopted — 20 May 2026;

•          the date the decision was officially published — 1 July 2026;

•          the date the decision entered into force — 31 July 2026;

•          the date the technical regulation itself enters into force — 1 January 2028.

Commentary that gives a single date almost always conflates two different ones. The one to check is the last — it determines when your obligations begin.

A separate source worth bookmarking is the Eurasian Economic Commission’s register of technical regulations in force. It contains only operative regulations; those adopted but not yet in force do not appear in it.

The step-by-step algorithm: from the idea of importing to the register entry

What follows is a sequence of sixteen steps in which each one only makes sense once the previous one is done. The commonest cause of lost time and money is starting at step 14 — calling a conformity confirmation body — without having done steps 1 to 3.

1.        Determine the EAEU HS code for the goods. Which technical regulation applies turns on it. An error in the code at this stage propagates through everything else.

2.        Check which Union technical regulations cover the goods. Use the register of technical regulations in force: it contains only operative regulations. There may be more than one — an electric kettle, for instance, falls under both the low-voltage equipment regulation and the electromagnetic compatibility regulation.

3.        If no Union regulation applies, check the Unified List and national requirements. The absence of an EAEU regulation does not mean no conformity confirmation is needed: paragraph 3 of the Protocol on technical regulation expressly leaves such objects to national law.

4.        Open the text of the applicable regulation and find its conformity assessment section. Only the regulation determines the form of confirmation — declaring or certification — and only it sets the applicable scheme and the range of applicants.

5.        Establish which system of standard schemes the regulation falls under. Adopted before 18 July 2018 and not amended as to schemes — Decision of the CU Commission No. 621 applies. Adopted later, or brought across to the new schemes — Decision of the Council of the EEC No. 44.

6.        Determine the object of declaration: serial output, a batch or a single article. This decision governs everything that follows: the range of applicants, the composition of the file, the validity of the document.

7.        Determine who the applicant will be. On import of serial goods into Kazakhstan — only a person authorised by the manufacturer. On import of batches — only the importer. If no suitable resident person exists, one must be created or appointed before the procedure begins.

8.        If the applicant is a person authorised by the manufacturer, conclude a contract with the manufacturercontaining two mandatory terms: assurance that the supplied products conform to the requirements of the regulation, and liability for non-conformity.

9.        Register the product in the National Catalogue of Goods and obtain the identification code. Without it the application under paragraph 71 of the Rules on conformity assessment is incomplete.

10.    Assemble the technical documentation and arrange its translation into Russian and, where necessary, into Kazakh. Translation is required by paragraph 27 of the standard schemes.

11.    Determine the list of standards to be applied. Applying standards from the list approved by the Commission is a sufficient condition of compliance with the regulation. If standards are not applied, a description of the technical solutions adopted and of the risk assessment results will be needed.

12.    Choose an accredited laboratory and check it against the single register of Union conformity assessment bodies and the Kazakh register of accredited bodies. Check both inclusion and scope of accreditation.

13.    Carry out identification and sampling, then testing. Under the national Rules, where testing periods are not set by the regulation or by standardisation documents, thirty calendar days may not be exceeded.

14.    Choose a conformity confirmation body and check it as carefully as the laboratory. Conclude a contract — the work is carried out only on a contractual basis.

15.    File the application. For a declaration under an EAEU regulation, under the Procedure approved by Decision of the Board of the EEC No. 41: a review period of no more than three working days. For a national declaration, through the digital technical regulation system: no more than five working days. An electronic digital signature is mandatory in both cases.

16.    Wait for the register entry, and only then apply the EAC mark and release the goods into circulation.Paragraph 1 of Article 22 of Law 396-VI: “Conformity assessment of products released into circulation against the requirements of technical regulations and (or) standardisation documents is carried out before their release into circulation, unless the technical regulation provides otherwise.”

What to do after registration

The procedure does not end with the register entry. Three obligations arise precisely at that point.

Ensure the products conform to what was declared. Sub-paragraph 2 of paragraph 7 of Article 17 of the Law: the person who adopted the declaration must ensure that the products in respect of which the declaration was adopted and registered conform to the requirements of technical regulations.

State the document’s particulars in the accompanying documentation. Sub-paragraph 4 of paragraph 2 of Article 31 of the Law expressly requires the accompanying documentation to state the particulars of the certificate or declaration.

Retain the evidence file. Ten years under Union law; three years from expiry under the national Rules.

Separately: goods manufactured in Kazakhstan

The sequence is almost the same, with two differences. The manufacturer can be the applicant itself — the residence requirement is met automatically. And instead of translating documentation you will need to produce it: technical documentation setting out the main parameters and characteristics of the product is a mandatory element of the file under sub-paragraph (a) of paragraph 26 of the standard schemes.

Manufacturers siting production in special economic zones and industrial zones should note that paragraph 2 of Article 39 of Law 396-VI takes projects on SEZ territory outside the general procedure for recognising foreign conformity assessment documents. The regime of the zones themselves is examined in Kazakhstan’s special economic zones and industrial zones.

Common mistakes and what each one costs

The ten mistakes below share one feature: each regularly ends in refusal of registration, annulment of a document or a fine. The cost is given for each.

1. A foreign manufacturer tries to be the applicant itself

A company in Germany, Turkey or China signs a declaration in its own name and hands it to its distributor in Kazakhstan. The document will not be registered: both Law 396-VI and the standard schemes require the applicant to be registered under the legislation of Kazakhstan or another Union member state.

Cost: refusal of registration under sub-paragraph (d) of paragraph 12 of the Procedure (applicant outside the permitted range) and the loss of the whole preparation period — usually four to eight weeks. If the goods have already arrived, they sit in the warehouse until a valid document exists.

2. An importer declares serial output

An importer draws up a declaration for “serial output” to cover all future supplies at once. Schemes 1d and 3d admit only the manufacturer or a person authorised by the manufacturer as applicant; an importer is admitted only by schemes 2d and 4d — that is, only for a batch or a single article.

Cost: refusal of registration; and if the document was registered after all, its annulment under paragraph 20 of Article 44 of the Law and a fine under part 1 of Article 415 of the Administrative Offences Code of up to 600 MCI (KZT 2,595,000) for a large enterprise.

3. Buying a document “without samples and in one day”

An offer to draw up a declaration within twenty-four hours without sampling is incompatible with schemes 3d, 4d and 6d, which require testing in an accredited laboratory, and with Section VI of the standard schemes, which governs identification and sampling. Paragraph 85 of the national Rules sets a ceiling of thirty calendar days for testing — it fixes no minimum, but it does show the order of magnitude.

Cost: in May 2026 Kazakhstan invalidated 1,113 certificates and declarations issued in Union states; in the regulator’s words, “certain documents were issued without carrying out the necessary testing of products” and “in a number of cases they were drawn up remotely”. For the owner of the goods the consequence is that the products count as released into circulation without conformity assessment. A fine under part 1 of Article 415 of up to KZT 2,595,000, and on a repeat within a year up to KZT 5,190,000, with possible confiscation of the products and suspension of activity.

4. Not checking the document against the register

A counterparty sends a scan of a declaration with a number and a seal, the contract is signed and the goods travel. There is no register entry.

Cost: paragraphs 4 and 9 of Article 17 of Law 396-VI expressly prohibit the use of such documents. The regulator gave a concrete example: in Shymkent, on an attempt to import chocolate glaze from Germany, a declaration issued in Kyrgyzstan but absent from the EAEU single register was found; the document’s validity was terminated. Meanwhile the goods sit in temporary storage with all the costs that entails.

5. Using a batch declaration for the next consignment

A declaration under scheme 2d or 4d is tied to a specific batch identified by the shipping documents, including its size. A second consignment of the same goods is not covered — unless the regulation permits test results to be used for similar batches and the applicant has carried out identification for similarity.

Cost: the second batch has been released into circulation without a document — the offence under sub-paragraph 2 of part 1 of Article 415, up to KZT 2,595,000.

6. Applying the EAC mark before the register entry

Marking is applied at the factory, the goods are shipped, and the document is still being registered. Section 4 of the Procedure on the mark confers the right to mark only where the products have passed all the established procedures, and paragraph 1 of Article 22 of the Law requires conformity assessment before the products are released into circulation.

Cost: breach of paragraph 5.4 of the Procedure (marking capable of misleading as to the meaning of the mark) plus the offence under part 1 of Article 415. In practice, the need to re-mark the whole batch — which for products with printed packaging means repackaging.

7. Marking only in the language of the country of production

Paragraph 6 of the Protocol on technical regulation requires marking in Russian and, where national legislation so requires, in the state language of the member state where the products are sold.

Cost: the breach is visible to an inspector without expert examination and without laboratory testing. It is the most easily detected category of breach, and it falls under sub-paragraph 1 of part 1 of Article 415 as non-conformity with the requirements of the regulation.

8. Trying to correct a registered declaration

A typographical error is found in the product name and the applicant asks the body to “make a correction”. Paragraph 14 of the Procedure: “Amendments may not be made to a registered declaration of conformity.”

Cost: there is no direct monetary cost, but there is a cost to not knowing: typographical errors are on the list of cases for replacement without repeat testing under paragraph 114 of the standard schemes. Companies unaware of that mechanism repeat the testing and pay for it twice — usually hundreds of thousands of tenge and several weeks.

9. Retaining evidence for three years instead of ten

A company works to paragraph 5 of Article 34 of Law 396-VI and destroys the file three years after the declaration expires. For a declaration under an EAEU regulation, paragraph 123 of the standard schemes applies — ten years from the date of registration.

Cost: on inspection there is nothing to produce. Paragraph 124 of the standard schemes obliges the evidence file to be produced on demand by state control bodies. Absence of evidence leads straight to annulment of the document under paragraph 20 of Article 44 of the Law.

10. Ignoring the lapse of a management system certificate under scheme 6d

A company declares under scheme 6d, saving on part of the testing, and then does not renew its management system certificate. The standard schemes require the applicant to terminate the declaration itself where it holds no valid management system certificate, including where the certificate has been suspended.

Cost: from the moment the management system certificate lapses, products are released into circulation under a declaration whose foundation has fallen away. A fine under Article 415, and on a repeat offence 1,200 MCI (KZT 5,190,000) for a large enterprise with possible suspension of activity.

Who this suits, who it does not, and when to get professional review

The right structure turns on three things: where the goods come from, whether supplies are regular, and whether you have a resident entity in Kazakhstan or another Union state. What follows is a breakdown by situation.

Foreign manufacturer, regular supplies to Kazakhstan

Suits: appointing a person authorised by the manufacturer and declaring serial output under scheme 1d, 3d, 5d or 6d, depending on which scheme the regulation prescribes.

What you will need: a resident person in Kazakhstan or another Union state; a contract with it containing terms on assurance of conformity and on liability for non-conformity; technical documentation with a translation; registration of the product in the National Catalogue.

What it gives you: one document covering the whole serial output for up to five years, instead of a document for each batch.

Importer, one-off or irregular supply

Suits: declaring a batch under scheme 2d or 4d. The importer is the applicant in its own name.

What you will need: a contract and shipping documents identifying the batch, including its size; testing under scheme 2d at the applicant’s choice in an accredited laboratory or in the manufacturer’s own laboratory, and under scheme 4d in an accredited laboratory only.

What it gives you: a batch declaration has no validity period under paragraph 112 of the standard schemes — it is tied to a quantity rather than a calendar. For seasonal or one-off imports that is cheaper and faster than the serial route.

Manufacturer in Kazakhstan

Suits: whichever scheme the regulation prescribes. The residence requirement is satisfied automatically.

What you will need: development of technical documentation setting out the main parameters and characteristics of the product; production control where the scheme requires it; under scheme 6d, a certified and continuously maintained management system.

What it gives you: the ability to circulate products throughout the Union market — EAC marking is valid in all five member states.

Who this does not suit

Companies with no resident entity and no plans for one. Without a legal entity or individual entrepreneur registered in Kazakhstan or another Union state, neither a declaration nor a certificate is available at all. The first step there is not certification but structure.

Sellers of second-hand goods. Paragraph 4 of Article 26 of the Law takes second-hand products outside mandatory conformity confirmation unless a regulation provides otherwise. Paying for a procedure that is not required is a common error.

Importers of medicines and medical devices. Those categories are excluded from the objects of technical regulation by paragraph 2 of Article 3 of the Law. They need a different regime — state registration within the healthcare system.

When professional review is needed

There are four situations in which deciding alone costs more than a consultation.

The goods fall under two or more regulations. Paragraph 106 of the standard schemes allows a single declaration, but only where the form of conformity confirmation is the same under all of them. If one requires declaration and another certification, there will be two documents — and that has to be established before testing is ordered.

The goods sit on the boundary of a regulation’s scope. Power, voltage, composition, intended use — a single parameter decides whether the goods are covered. An error here costs either unnecessary procedures or a fine.

A change of legal form, address or name is planned. Paragraph 81 of the national Rules requires a new declaration in those cases, while paragraph 114 of the standard schemes allows a Union declaration to be replaced without repeat testing. The difference between the two regimes is real money.

The products are covered by a regulation not yet in force. Alcohol until 1 January 2027, paints and varnishes until 1 January 2028, energy-consuming devices until 1 September 2028, chemical products and mineral fertilisers with no fixed date. Those categories are under a different regime today, but planning has to be done against the future one.

How we can help

UPPERSETUP works with companies entering the Kazakh and wider EAEU market at all three levels needed to sell goods lawfully.

The structure of presence. To be the applicant you need a resident entity. We select and register the right form — a limited liability partnership, a branch or a representative office. One of the things that has to be weighed is paragraph 3 of Article 43 of the Civil Code of the Republic of Kazakhstan: “Branches and representative offices are not legal entities”, while Article 1 of Law 396-VI requires the importer and the person authorised by the manufacturer to be a legal entity or an individual entrepreneur. A representative office does not answer that definition. That is what the company registration service and the Kazakhstan country page are for.

The contractual base. The contract between a foreign manufacturer and its authorised person must contain the two mandatory terms from sub-paragraph (c) of paragraph 5 of the EEC Procedure — assurance of conformity and liability for non-conformity. Drafting such contracts and the obligations around them belongs to legal support.

Record-keeping and reporting after market entry. Product data must reconcile across the declaration of conformity, the National Catalogue of Goods, electronic invoices and the customs documents. Setting up that loop is what accounting support is for.

The conformity confirmation procedure itself is carried out by an accredited conformity confirmation body, and by law nobody can substitute for it. Our role is to make sure that by the time you approach such a body you have the right structure, the right applicant and a complete document set.

Frequently asked questions

Do I need a certificate, or is a declaration enough?

The technical regulation decides, not the applicant. Paragraph 3 of Article 26 of Law 396-VI: mandatory conformity confirmation is carried out only in the cases established by the relevant technical regulation. The one general exception is paragraph 3 of Article 25 of the Law: conformity of a technically complex article or product is confirmed by certification unless the regulation provides otherwise.

Can a foreign company draw up a declaration for Kazakhstan itself?

No. The applicant must be a legal entity or individual entrepreneur registered under the legislation of the Republic of Kazakhstan or another EAEU member state. A foreign manufacturer acts through a person authorised by the manufacturer (for serial goods) or through an importer (for batches).

How long does registering a declaration take?

Registration takes three working days for a declaration under an EAEU technical regulation and five working days for a national Kazakh declaration. But that is registration only. Under the national Rules testing must not exceed thirty calendar days unless the regulation provides otherwise, and preparing the documentation takes several weeks upwards.

What does registering a declaration cost in Kazakhstan?

There is no state duty for registering a declaration of conformity in Kazakhstan. Paragraph 1 of Article 664 of the Tax Code of the Republic of Kazakhstan of 18 July 2025 No. 214-VIII contains a closed list of sixteen objects attracting state duty — court filings, notarial acts, emigration papers, invitations and visas, citizenship documents, a hunter’s licence, identity documents, weapons, the apostille, driving licences and vehicle registration, number plates, pyrotechnics and a residence permit. Conformity assessment, declarations and certificates appear nowhere in it. The applicant pays only the conformity confirmation body and the testing laboratory under contract. Paragraph 13 of the EEC Procedure expressly leaves the question of payment to national law.

How long is a declaration of conformity valid?

An EAEU declaration for serially produced goods lasts no more than five years; for a batch of goods no validity period is set at all. A national Kazakh declaration is adopted for the period set by the manufacturer on the basis of the planned period of output; the Rules impose no ceiling.

What happens to warehouse stock if the declaration expires?

Nothing. Conformity assessment documents are valid in respect of each unit of product released into circulation while the document was in force, for the duration of that product’s shelf life or service life. The rule was introduced by the Protocol of 31 March 2022 and has applied since 12 February 2024. Expiry closes off the release of new units; it does not make units already released unlawful.

Can a typographical error in a registered declaration be corrected?

Corrected, no: paragraph 14 of the EEC Procedure expressly prohibits amendments to a registered declaration. But typographical errors are on the list of cases for replacing a declaration without repeat testing under paragraph 114 of the standard schemes. The new document takes the same expiry date as the one it replaces.

Does the EAC mark have to go on every unit of goods?

Paragraph 5.1 of the Procedure on the mark: the mark is applied to each unit of product, to the packaging or to the accompanying documentation. The conjunction is disjunctive. But paragraph 5.3 refers to the particular technical regulation, which may impose a stricter requirement — and it is the regulation that needs checking.

What is the minimum size of the EAC mark?

The base size must be no less than 5 mm. The dimensions are determined by the manufacturer, the authorised person or the importer, and must guarantee the clarity of the mark’s elements and their distinguishability by the naked eye against the general coloured background of the object.

Is a declaration registered in Russia or Armenia valid in Kazakhstan?

Yes, provided it is registered under a Union technical regulation, entered in the single register, and the body that registered it is included in the single register of Union conformity assessment bodies with an appropriate scope of accreditation. Section 4 of the Procedure on the EAC mark refers expressly to procedures passed “on the territory of any of the member states of the Eurasian Economic Union”.

How do I check that a document is genuine?

Find it in the register. For documents under Union regulations, in the single register of issued certificates of conformity and registered declarations of conformity on the official site of the Union. For national Kazakh documents, in the technical regulation register in the e-KTRM digital system. If the document is not in the register it legally does not exist, and using it is prohibited by paragraphs 4 and 9 of Article 17 of Law 396-VI.

Is a declaration needed for second-hand goods?

As a general rule, no. Paragraph 4 of Article 26 of Law 396-VI takes second-hand products outside the objects of mandatory conformity confirmation, and paragraph 2 of Article 3 excludes them from the objects of technical regulation altogether. The qualification “unless technical regulations provide otherwise” matters here: individual regulations contain their own requirements.

What is the fine for selling goods without conformity assessment documents?

Under part 1 of Article 415 of the Kazakh Administrative Offences Code: 90 MCI for individuals, 195 MCI for officials, small business entities and non-profit organisations, 310 MCI for medium-sized business and 600 MCI for large business. On a repeat offence within a year: 135, 360, 600 and 1,200 MCI respectively, with or without suspension of activity and with or without confiscation of the products. At the 2026 monthly calculation index of KZT 4,325 the maximum fine on a large enterprise is KZT 5,190,000.

What to take away

•          The form of conformity confirmation is set by the technical regulation, not by the applicant or the body.Paragraph 3 of Article 26 of Law 396-VI: mandatory conformity confirmation is carried out only in the cases established by the relevant regulation and exclusively as to compliance with its requirements.

•          A foreign company cannot be the applicant. Both Law 396-VI and the standard schemes require the applicant to be registered under the legislation of Kazakhstan or another Union member state. On import of serial goods the applicant must be a person authorised by the manufacturer; on import of batches, the importer.

•          An importer cannot declare serial output. Schemes 1d, 3d, 5d and 6d admit only the manufacturer or a person authorised by it. A seller (importer) is admitted only by schemes 2d and 4d — that is, only for a batch or a single article.

•          Legal significance attaches to the register entry, not to the paper. A declaration is treated as registered from the date a registration number is assigned, and as suspended, resumed or terminated from the date the corresponding information is entered in the register.

•          A document not in the register may not be used. Paragraphs 4 and 9 of Article 17 of Law 396-VI, reinforced by paragraph 2 of Article 35. The check takes two minutes and is needed not only at contract signature but regularly.

•          Expiry of a document does not make warehouse stock unlawful. Documents are valid in respect of each unit of product released into circulation while they were in force, for that product’s shelf life or service life.

•          A registered declaration cannot be corrected, but in seven cases it can be replaced without repeat testing.Typographical errors, a change of address, telephone or name while the registration number is retained, a change of HS codes — all are grounds for simplified replacement under paragraph 114 of the standard schemes.

•          Union law requires ten years of evidence retention; the Kazakh statute says three. For declarations under EAEU regulations, work to the ten-year period: paragraph 2 of Article 2 of Law 396-VI gives priority to a ratified international treaty.

•          Two systems of standard schemes run in parallel in the EAEU. Decision of the CU Commission No. 621 for regulations adopted before 18 July 2018; Decision of the Council of the EEC No. 44 for those adopted later. The “1d to 6d” labels belong only to the second system.

•          Not everything is governed by technical regulations. Medicines, medical devices, veterinary preparations, civil aviation products, second-hand goods and several other categories are excluded from the objects of technical regulation. They have a different regime, often a stricter one.

•          Five regulations have been adopted but are not yet operative. Alcoholic products from 1 January 2027; paints and varnishes from 1 January 2028; energy efficiency from 1 September 2028; chemical products and mineral fertilisers with no fixed date.

•          The procedure is fully digital. A national declaration exists only in electronic form signed with an electronic digital signature; the application is filed in the digital technical regulation system; and it requires a product identification code from the National Catalogue of Goods.

•          The most expensive risk is a “grey” document. 1,113 certificates and declarations invalidated, more than 42,000 conformity confirmation documents annulled in six months, 20 accreditation certificates suspended, 76 websites blocked. Liability for release into circulation attaches to whoever released the goods, not to whoever issued the document.

Summary

To sell goods lawfully in Kazakhstan in 2026 you must confirm their conformity with the requirements of the applicable technical regulation and have the document entered in the register. The form of confirmation — declaring or certification — is determined by the technical regulation itself; as at September 2026 the EAEU has adopted 53 technical regulations, of which 48 are in force and cover more than 85% of products on the market. Five are not yet in force: TR EAEU 039/2016, 041/2017, 047/2018 (from 1 January 2027), 048/2019 (from 1 September 2028) and 053/2026 (from 1 January 2028). Only a person registered under the legislation of Kazakhstan or another Union member state can be the applicant: on import of serial goods, a person authorised by the manufacturer; on import of batches, the importer. Declaration schemes 1d, 3d, 5d and 6d are available only to the manufacturer and its authorised person; schemes 2d and 4d additionally admit a seller (importer), but only for a batch or a single article. A declaration under an EAEU technical regulation is registered within three working days under the Procedure approved by Decision of the Board of the EEC of 20 March 2018 No. 41 and lasts no more than five years for serial goods; for a batch no validity period is set. A national declaration of the Republic of Kazakhstan is registered by a conformity confirmation body in the digital technical regulation system within five working days under the Rules on conformity assessment approved by order of the Minister of Trade and Integration of 29 June 2021 No. 433-NQ; it exists only in electronic form signed with an electronic digital signature, and the application must state the EAEU HS code and the product identification code from the National Catalogue of Goods. Products are marked with the single EAC mark of circulation, base size no less than 5 mm, applied to each unit of product, to the packaging or to the accompanying documentation; the marking is in Russian and, in Kazakhstan, also in Kazakh as the state language. Documents confirming conformity are valid in respect of each unit of product released into circulation while they were in force, for that product’s shelf life or service life — a rule introduced by the Protocol of 31 March 2022, in force from 12 February 2024. The evidence file is retained by the applicant for ten years from registration under paragraph 123 of the EAEU standard schemes and for three years from expiry under paragraph 5 of Article 34 of the Law of the Republic of Kazakhstan of 30 December 2020 No. 396-VI. Using a document about which the register holds no information is prohibited; releasing products into circulation without conformity assessment documents attracts a fine under Article 415 of the Kazakh Administrative Offences Code of 90, 195, 310 or 600 monthly calculation indices depending on the subject, and 135, 360, 600 or 1,200 MCI on a repeat offence within a year — at the 2026 index of KZT 4,325 that is up to KZT 5,190,000 for a large business entity.

Sources and method of verification

Every figure, date and formulation in this article comes from a primary text — instruments on official legislation portals and official statements by the regulator. Dates of adoption and dates of entry into force are given separately. What follows is the full list of sources used, with an indication of what was taken from each.

Law of the Eurasian Economic Union

1.        Treaty on the Eurasian Economic Union of 29 May 2014 — the founding instrument, Section X on technical regulation.

2.        Protocol on technical regulation within the Eurasian Economic Union (Annex No. 9 to the Treaty) — paragraphs 2 to 11: definitions, the boundary between the tiers of regulation, lists of standards, the range of applicants, the electronic form of documents, validity of a document in respect of each unit of product, the single registers, the single mark of circulation, the Unified List and the import procedure.

3.        Protocol of 31 March 2022 amending the Treaty on the EAEU — status “In force”, entry into force 12 February 2024.

4.        Protocol of 28 July 2025 amending the Treaty on the EAEU — status “Not in force”; sub-paragraph 4 of Article 1 on clarifications by the Commission.

5.        Decision of the Council of the Eurasian Economic Commission of 18 April 2018 No. 44 “On standard conformity assessment schemes” — standard schemes 1d to 6d, composition of the evidence file, validity periods, replacement of declarations, retention periods; as amended by Decisions No. 127, No. 8, No. 107 and No. 11.

6.        Decision of the Customs Union Commission of 7 April 2011 No. 621 — the Regulation on applying standard schemes to regulations adopted before 18 July 2018.

7.        Decision of the Board of the Eurasian Economic Commission of 20 March 2018 No. 41 — the Procedure for registration, suspension, resumption and termination of declarations of conformity; the three-day period, grounds for refusal, the prohibition on amendments.

8.        Decision of the Board of the Eurasian Economic Commission of 25 December 2012 No. 293 — the single forms of certificate of conformity and declaration of conformity and the rules for drawing them up; as amended by Decisions No. 154 and No. 198.

9.        Decision of the Customs Union Commission of 7 April 2011 No. 620 — the Unified List of products; the current title and the chain of nineteen amendments.

10.    Decision of the Customs Union Commission of 15 July 2011 No. 711 — the single mark of product circulation on the EAEU market and the procedure for applying it.

11.    Decision of the Council of the Eurasian Economic Commission of 20 May 2026 No. 65 — adoption of TR EAEU 053/2026; the dates of adoption, publication and entry into force.

12.    Text of Decision of the Council of the EEC of 20 May 2026 No. 65 — paragraph 2 on the dates of entry into force of the regulation and on the lead content rule.

13.    Decision of the Council of the Eurasian Economic Commission of 20 May 2026 No. 62 — moving the entry into force of TR EAEU 047/2018 to 1 January 2027.

14.    Register of adopted technical regulations of the Eurasian Economic Commission — 53 entries; counted on 16 September 2026.

15.    Register of technical regulations in force — 48 entries; counted on 16 September 2026.

16.    Databases in the field of technical regulation of the Eurasian Economic Commission — the addresses of the single registers.

17.    The single register of issued certificates of conformity and registered declarations of conformity on the EAEU portal — the address taken from the Eurasian Economic Commission’s index of databases; as at 16 September 2026 the page opens with the notice “The resource is being updated”. 17-1. The single register of issued certificates of conformity and registered declarations of conformity — an alternative entry point. 17-2. Decision of the Board of the Eurasian Economic Commission of 26 September 2017 No. 127 — the Procedure for forming and maintaining the single register; in force from 27 March 2018, as amended by Decision of the Board of the EEC of 4 April 2023 No. 46 (applying from 6 May 2023); paragraphs 14 and 15. 17-3. Decision of the Council of the Eurasian Economic Commission of 30 November 2016 No. 150 — paragraph 2: the conditions for the entry into force of TR EAEU 039/2016. 17-4. Decision of the Council of the Eurasian Economic Commission of 3 March 2017 No. 19 — paragraphs 2 and 4: the conditions for the entry into force of TR EAEU 041/2017. 17-5. Decision of the Council of the Eurasian Economic Commission of 8 August 2019 No. 114 — paragraph 3 as amended by Decision No. 54 of 8 July 2025: the entry into force of TR EAEU 048/2019. 17-6. Decision of the Council of the Eurasian Economic Commission of 25 January 2023 No. 11 — amendments to the standard schemes; in force from 26 February 2023.

Legislation of the Republic of Kazakhstan

18.    Law of the Republic of Kazakhstan of 30 December 2020 No. 396-VI “On technical regulation” — Articles 1, 2, 3, 9, 13, 17, 18, 22, 24, 25, 26, 27, 31, 32, 33, 34, 35, 39, 44, 47 and 48; dates of official publication and the chain of amendments.

19.    Code of the Republic of Kazakhstan on Administrative Offences of 5 July 2014 No. 235-V — Articles 415, 415-1 and 416 in their operative versions.

20.    Order of the acting Minister of Trade and Integration of the Republic of Kazakhstan of 29 June 2021 No. 433-NQ “On approval of the Rules on conformity assessment” — paragraphs 4, 7, 8-1, 67 to 81, 85 and 87; the chain of amendments including order No. 155-NQ of 1 April 2026.

21.    Law of the Republic of Kazakhstan of 8 December 2025 No. 239-VIII “On the republican budget for 2026–2028”— paragraph 4 of Article 7: monthly calculation index of KZT 4,325 from 1 January 2026.

22.    Law of the Republic of Kazakhstan of 5 July 2008 No. 61-IV “On accreditation in the field of conformity assessment” — the legal basis of accreditation.

23.    Law of the Republic of Kazakhstan of 5 October 2018 No. 183-VI “On standardisation” — the legal basis of standardisation documents. 22-1. Civil Code of the Republic of Kazakhstan (General Part) of 27 December 1994— paragraph 3 of Article 43: branches and representative offices are not legal entities. 23-0. Tax Code of the Republic of Kazakhstan of 18 July 2025 No. 214-VIII — paragraph 1 of Article 664: the closed list of sixteen objects attracting state duty, in which conformity assessment does not appear. 23-1. Order of the Minister of Trade and Integration of the Republic of Kazakhstan of 31 July 2025 No. 232-NQ “On approval of the Rules for maintaining the National Catalogue of Goods and for registering goods in it” — paragraphs 5, 7, 8, 14, 15, 16, 18, 20, 21, 22 and 23; as recast by order No. 284-NQ of 02.10.2025 and amended by order No. 153-NQ of 31.03.2026.

State information systems and registers

24.    The e-KTRM digital technical regulation system — the system’s portal.

25.    Register of declarations of conformity — the public part of the technical regulation register; checked on 16 September 2026.

26.    Register of certificates of conformity for products of the Republic of Kazakhstan — the public part of the register.

27.    Register of accredited bodies — the public part of the register.

28.    The “About the project” section of the digital technical regulation system — the composition of the registers and the system’s legal basis.

29.    National Accreditation Centre of the Republic of Kazakhstan — the accreditation body.

Official statements by the regulator

30.    Press conference at the Central Communications Service under the President of the Republic of Kazakhstan, 10 July 2026 — statement by the acting chairman of the Committee for Technical Regulation and Metrology Bauyrzhan Kasymov: 53 adopted and 48 operative technical regulations, more than 85% of products, 1,773 accredited subjects, 62 conformity confirmation bodies, 356 testing laboratories, 8,831 test reports bearing the ILAC MRA mark, about 76,000 standardisation documents, 57 standards under the National Plan, more than 1,148 state services, 45th place among 112 CIPM MRA participants, entry into force of the Kazakh coal regulation in March 2026.

31.    “Different standards are needed”, Kazakhstanskaya Pravda, 14 July 2026 — results of state control for the first half of 2026: more than seven thousand control measures, 4,267 cases of breach (56%), 2,490 enforcement notices, more than KZT 186 million in fines, 20 suspended accreditation certificates, more than 42,000 annulled conformity confirmation documents, a ban on sale of 867 wholesale consignments.

32.    “More than 1,100 invalid certificates identified in Kazakhstan”, Kazinform, 19 May 2026 — 1,113 documents declared invalid (742 Kyrgyzstan, 244 Russia, 11 Belarus), eight annulled accreditation certificates of Kyrgyz bodies, 76 blocked websites, the chocolate glaze example in Shymkent.

UPPERSETUP material on adjacent subjects

33.    Importing into Kazakhstan from third countries in 2026

34.    VAT on imports from the EAEU into Kazakhstan in 2026

35.    Permits and notifications in Kazakhstan in 2026

36.    E-invoices and the Virtual Warehouse in Kazakhstan in 2026

37.    LLP in Kazakhstan for foreigners in 2026

38.    Branch and representative office of a foreign company versus an LLP in Kazakhstan

39.    Kazakhstan’s special economic zones and industrial zones in 2026

Method and the limits of verification

Union instruments were read on Alta-Soft and the EAEU legal portal, with status and date of entry into force checked in each case; Kazakh instruments were read in the Adilet legal information system, with the footnotes on the manner of bringing them into operation checked.

One divergence between sources is worth naming. The Eurasian Economic Commission’s own page “Acts in the field of conformity assessment” carries Decision of the CU Commission No. 711 under its former title (“on the market of the member states of the Customs Union”) and lists only Decision of the CU Commission No. 800 of 23 September 2011 among the amending acts, omitting Decisions of the Council of the EEC No. 61 of 20 July 2012 and No. 22 of 17 March 2016. Alta-Soft is the fuller source on amendment chains; the Commission’s page remains authoritative on which acts exist at all, and on the registers of adopted and operative regulations. The count of technical regulations was made by enumerating the entries in two Eurasian Economic Commission registers on 16 September 2026 and matched the regulator’s official figure of 10 July 2026.

What this article deliberately does not state, because it is not supported by a primary source:

The number of technical regulations of the Republic of Kazakhstan in force. The “Technical regulations of the RK” section of the digital technical regulation system requires authorisation, and the Committee’s official briefings in 2026 do not give this figure. Any round number found in open sources is not supported by an official source.

The annual number of declarations registered and certificates issued in Kazakhstan. Neither the Committee for Technical Regulation and Metrology nor the Bureau of National Statistics publishes this indicator. Only indirect data are available: more than 42,000 documents annulled in the first half of 2026.

The phased timetable for bringing product categories into the National Catalogue of Goods. The Rules for maintaining the catalogue were read in their primary text and are set out in a separate section, but they contain no phased timetable for bringing categories into scope, and none was found in any other accessible official source.

The cost of the services of conformity confirmation bodies and testing laboratories. Prices are set by contract and are not regulated, except for the prices of the state monopoly entity in accreditation, which are set by the authorised body in agreement with the antimonopoly body.

No commercial certification service provider and no aggregator of offers to arrange documents has been used as a source in this article.

Updated: September 2026.

This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, individual professional advice should be obtained that takes into account the specific situation, the jurisdiction, the status of the company and the current requirements of the regulators.