Product Marking and Traceability in Kazakhstan: Motor Oils, Beer, Food Supplements and Light-Industry Goods, 2026–2029

Marking goods with means of identification means printing a two-dimensional DataMatrix code on the pack, behind which a state-run digital system keeps the history of that one physical unit from the production line to the till. In 2026 Kazakhstan moved from four product groups to more than twenty: beer, motor oils and food supplements joined tobacco, footwear, medicines and saiga derivatives, and light-industry goods start in December 2026. The practical answer is simple: if your product is on the list, you cannot import it or sell it without a marking code, and a retail till may process the sale only once the code has been scanned.

⚠️ The key risk as at September 2026. From 1 September 2026 mandatory marking was extended to lubricating oils, lubricants and special automotive fluids — fourteen EAEU HS codes instead of the previous four. Yet the sectoral Rules that explain how to do it were rewritten by Order No. 316-н/қ of the Minister of Energy of 24 August 2026 and take effect only sixty calendar days after their first official publication, which took place on 27 August 2026 — that is, from 27 October 2026. The duty to mark arose before the procedure for discharging it came into force. Participants in the lubricants market should proceed on the basis that the requirement already applies, not that it starts when the new edition of the Rules takes effect.

What the digital marking and traceability system is

The digital product marking and traceability system is the state information infrastructure in which participants in circulation are registered, marking codes are issued, and the application of codes to packaging, the introduction of goods into circulation, every transfer between owners and the withdrawal of goods from circulation at the till are all recorded.

The system has two names, and that is not editorial sloppiness but the residue of an unfinished terminology reform.

The Law of the Republic of Kazakhstan “On the Regulation of Trading Activity” uses the term “digital product marking and traceability system”. That concept is fixed in paragraph 36 of Article 1 of the Law, where marked goods are defined through “the national component of the digital product marking system”.

Subordinate acts adopted in 2026 use both variants. The Rules on motor oils in their January 2026 edition speak of the “information system of product marking and traceability” and use the abbreviation ИС МПТ. The Rules on beer, food supplements and light-industry goods, adopted later, already use the “digital system” and the abbreviation ЦС МПТ. The new edition of the Rules on lubricants of August 2026 completes the transition to the “digital system”, writing it out in full without any abbreviation.

The practical conclusion is that ИС МПТ and ЦС МПТ are the same object. The difference in name reflects nothing except the date on which a given act was adopted. In the market the system runs under the brand Tañba (tanba.telecom.kz), and the operator’s contact centre takes calls around the clock on 8 800 080 6565, free from mobile and landline numbers.

There is a third name that has nothing to do with marking, and people trip over it regularly. Order No. 123-НҚ of 30 March 2023 of the acting Deputy Prime Minister — acting Minister of Trade and Integration is titled “On approval of the Rules of registration in the digital system”. Despite the near-identical name, those Rules govern the registration of landlords of trading places in markets and large retail facilities through the egov.kz portal, the display of a QR code at the entrance to a retail facility, and the publication of the price per square metre. Registration of a participant in the circulation of marked goods is governed not by that act but by the sectoral Rules for each product group.

The legal framework in force as at 23 September 2026

Kazakhstan’s marking framework has four tiers: an EAEU treaty, the national statute, Government acts, and sectoral ministerial orders for each product group.

Tier one — supranational. The Agreement on the marking of goods with means of identification in the Eurasian Economic Union was concluded in Almaty on 2 February 2018 and ratified by Law of the Republic of Kazakhstan No. 230-VI of 1 March 2019. Article 8 of the Agreement contains a closed list of exemptions, and all four sectoral acts analysed below refer to it. Decisions of the Council of the Eurasian Economic Commission set the union-wide framework for individual groups: Decision No. 108 of 27 September 2023 on medicinal products, Decision No. 51 of 8 July 2025 on bicycles and bicycle frames, Decision No. 53 of 8 July 2025 on certain lubricating oils, lubricants and special automotive fluids, Decision No. 51 of 27 April 2026 on certain paint and varnish products, and Decision No. 64 of 20 May 2026 on food products for the nutrition of athletes.

Tier two — the statute. Law of the Republic of Kazakhstan No. 544-II of 12 April 2004 “On the Regulation of Trading Activity” carries the definitions (paragraphs 7, 31, 36, 41, 42, 43 and 45 of Article 1), the allocation of competence between the coordinating body, the sectoral authorised bodies and the Single Operator (Articles 7, 7-2, 7-3, 7-4 and 7-5), and the duties and prohibitions that bind business (Articles 31 and 32). Articles 7-2 to 7-5 were inserted by Law No. 241-VI of 2 April 2019; Article 7-4 was amended by Law No. 215-VIII of 18 July 2025 with effect from 1 January 2026.

Tier three — Government acts. Government Resolution No. 95 of 3 March 2020 designated joint-stock company Kazakhtelecom as the Single Operator of product marking and traceability. Government Resolution No. 31 of 2 February 2021 set out four functions of that operator. Government Resolution No. 1013 of 27 November 2025 approved the Trade Policy Concept of the Republic of Kazakhstan to 2030 — a document that expressly plans both the expansion of the list and the introduction of liability for selling unmarked goods.

Tier four — sectoral orders. The list of goods is determined by the Ministry of Trade and Integration; the marking procedure for each group is set by the relevant ministry: Energy for lubricants, Finance for beer, Health for food supplements, Industry and Construction for light-industry goods.

The chain of the list runs as follows. At first the Government approved it: Resolution No. 568 of 10 September 2020, as amended by Resolution No. 588 of 31 August 2021 — both resolutions have been repealed and are cited here only as a historical link in the chain. The power then passed to the authorised body under sub-paragraph 2-4) of Article 7 of the Law; that sub-paragraph provides that the authorised body “determines the list of goods subject to marking and the date of its introduction”.

What follows are two separate orders of the Ministry of Trade and Integration, and as at 23 September 2026 the Adilet database records both as being in force.

The first is Order No. 343-НҚ of the acting Minister of Trade and Integration of 27 September 2024(registered with the Ministry of Justice on 27 September 2024 under No. 35129). Its title, paragraph 1 and annex are set out in the edition of Order No. 330-НҚ of 22 November 2025, as amended by Order No. 128-НҚ of 11 March 2026. The list in that order contains 84 entries and runs as far as light-industry goods.

The second is Order No. 199-НҚ of the Minister of Trade and Integration of 26 May 2026, whose annexed list was restated by Order No. 215-НҚ of 30 June 2026 and restated again by Order No. 253-ОД of the Minister of Trade and Integration of 4 September 2026. That list contains 292 entries and sets dates out to May 2029.

The operative edition of the list at the date of this article is the annex to Order No. 253-ОД of 4 September 2026. Paragraph 2 of that order reads: “This order shall enter into force on the day of its signing.”

⚠️ A practical trap. As at 23 September 2026 the consolidated text of Order No. 199-НҚ on the Adilet portal is presented in the edition of Order No. 215-НҚ and does not yet reflect the changes made by Order No. 253-ОД. Both texts contain 292 entries, and for beer, oils, food supplements and light-industry goods the dates coincide — but the wording of the food-product rows (entries Nos. 254–273) differs. If you work with food products, read the annex to Order No. 253-ОД rather than the consolidated text.

A separate strand is the National Product Catalogue. Its maintenance is governed by Order No. 232-НҚ of the Minister of Trade and Integration of 31 July 2025 (registered with the Ministry of Justice on 31 July 2025 under No. 36544), adopted under sub-paragraph 15-12) of Article 7 of the Law. The Rules are set out in the edition of Order No. 284-НҚ of 2 October 2025 (in force from 1 January 2026), and individual paragraphs were amended by Order No. 153-НҚ of the acting Minister of Trade and Integration of 31 March 2026 with effect from 12 July 2026.

The Single Operator and its powers

The Single Operator of product marking and traceability is the legal entity designated by the Government to build and run the digital marking system, issue means of identification, maintain the registers and register goods in the National Product Catalogue.

Kazakhstan’s Single Operator is joint-stock company Kazakhtelecom. Paragraph 1 of Government Resolution No. 95 of 3 March 2020 reads: “To designate joint-stock company ‘Kazakhtelecom’ as the Single Operator of product marking and traceability.” The resolution was adopted under sub-paragraph 11-2) of Article 6 of the Law and applies from the day of first official publication.

The operator’s competence is fixed in paragraph 1 of Article 7-4 of the Law and covers five core blocks, a separate block on services to fiscal data operators, and a residual reference to other functions: development, implementation, administration, support and operational maintenance of the digital system; security of digital resource storage; issuance and accounting of means of identification; services for applying a means of identification to a physical carrier; registration of goods in the National Product Catalogue and updating of the data; services to fiscal data operators for using the Catalogue, including verification of the identification code and access to product registration through cash registers; and other functions provided for by law.

Paragraph 2 of Article 7-4 imposes resource requirements on the operator, and one of them works directly in favour of small business. Sub-paragraph 6) requires “equipment for printing means of identification onto a physical carrier, made available to manufacturers that are small business entities of the Republic of Kazakhstan under property hire (lease), financial lease or other financial instruments”. Sub-paragraph 2) requires branches, representative offices or other structural units down to the level of district administrative centres across the country — precisely in order to provide the code-application service.

Government Resolution No. 31 of 2 February 2021 adds four functions: interaction with the EAEU integrated information system in the field of marking; uninterrupted access for participants in circulation; the conclusion of contracts with third parties and delegation to subsidiaries of the consolidation of contractual relations and settlements; and approval of standard-form contracts, instructions and other documents governing the organisational and technical aspects of the system and the Catalogue.

That last point matters commercially. The standard-form contract with the operator is approved by the operator itself, not by a ministry. Commercial terms of connection, integration and code payment are therefore shaped contractually, while the only regulated element is the ceiling price of a code.

The list of goods: 292 entries, and why an HS code alone is not the answer

The list of goods subject to marking and the date of its introduction is a four-column table: serial number, EAEU HS code, description of the goods, and the date on which marking becomes mandatory.

The operative edition of the list contains 292 entries. That is not 292 product groups — a single group can occupy dozens of rows, because each EAEU HS code takes a row of its own.

The principal methodological error in reading the list is to assume that the HS code determines the duty. The list itself guards against that error. The motor-oil rows state: “For goods classified under the said EAEU HS positions, regard must be had both to the EAEU HS code and to the name of the goods.” The same rule is repeated in paragraph 15 of the Rules on motor oils.

This is not a formality. In the operative list, code 2710 19 820 0 generates two different dates: motor oils under that code are marked from 1 February 2026, while other lubricating oils, lubricants and special automotive fluids under the same code are marked from 1 September 2026.

The second feature is that the duty is tied not only to the date of introduction but also to the date of manufacture. The formulations differ between groups, and the difference is critical:

The distinction has direct financial consequences. For beer, oils and food supplements, goods manufactured before the relevant date fall outside the duty — but you must be able to prove the manufacturing date from the pack and from your records. Light-industry goods get no such relief: what matters is the fact of import or manufacture, and stock on hand is dealt with separately and to its own deadline.

The full marking calendar to 2029

Kazakhstan’s marking calendar runs from October 2020 to May 2029 and covers more than twenty product groups.

The operator’s Tañba portal confirms this from the practical side: mandatory marking is already live for tobacco products, footwear, medicines, derivatives, brewing products, motor oils and food supplements; light-industry goods and jewellery are in pilot status; timber, household gas, household chemicals, cosmetics, medical devices, vegetable oil and confectionery are flagged as coming next.

Two lists in force: which one applies

As at 23 September 2026 two orders of the Ministry of Trade and Integration are formally in force in Kazakhstan, each of which determines the list of goods subject to marking and the date of its introduction. This is not a portal error: both acts are recorded in the Adilet database as being in force, and neither has been repealed.

The first is Order No. 343-НҚ of 27 September 2024 (84 entries). The second is Order No. 199-НҚ of 26 May 2026 as restated by Orders No. 215-НҚ and No. 253-ОД (292 entries).

Where they diverge

The principal divergence is bottled beer.

Footnote ***** to the list in Order No. 343-НҚ reads: “mandatory marking in respect of beer and beer beverages manufactured from 1 February 2026 supplied in kegs and bottles, from 1 January 2027 poured into cans”.

Entries Nos. 37–39 of the list in Order No. 253-ОД read differently: “poured into kegs, manufactured from 1 February 2026 — from 1 February 2026; poured into bottles, manufactured from 1 September 2026 — from 1 September 2026; poured into cans, manufactured from 1 January 2027 — from 1 January 2027.”

For one and the same product, in other words, two acts in force give different dates: 1 February 2026 against 1 September 2026.

The second divergence concerns medicinal products. Order No. 343-НҚ has a separate group dated 1 July 2022: entries Nos. 13–21, covering immune sera and fractions of human blood (codes 3002 12 000 5, 3002 12 000 9, 3002 15 000 0, 3002 90 300 0) and medicinal products under codes 3004 20 000, 3004 39 000, 3004 49 000, 3004 90 000 and 3004 90 000 2. Order No. 199-НҚ has no such date at all: entries Nos. 13–35 are consolidated under 1 July 2024.

The third divergence is scope. Order No. 343-НҚ contains no food supplements, no jewellery, no perfumery, no vegetable oils, no confectionery, no toys, no instant beverages, no antimicrobial cosmetics, no food products and no canned products.

How the conflict is resolved in law

The rule is set out expressly in paragraph 3 of Article 12 of the Law of the Republic of Kazakhstan No. 480-V of 6 April 2016 “On Legal Acts”: “Where there are contradictions between the provisions of a single regulatory legal act or of regulatory legal acts of the same level, the provision of the act introduced into force later, or the provision that corresponds to the act introduced into force later, shall apply.”

Both orders are subordinate acts of the same level, issued by the same body under the same sub-paragraph 2-4) of Article 7 of the Law on the Regulation of Trading Activity. Order No. 199-НҚ took effect later, and its list was restated by Order No. 253-ОД, which entered into force on 4 September 2026. Order No. 199-НҚ as restated by Order No. 253-ОД therefore prevails: bottled beer is marked from 1 September 2026.

For completeness, paragraph 1 of the same Article 12 governs a different case: where acts of different levels conflict, the act of the higher level prevails.

Why one order is registered with the Ministry of Justice and the other is not

A reader who opens both acts will notice a difference in the formal particulars: Order No. 343-НҚ carries a state registration number (No. 35129), Order No. 199-НҚ does not. That is not a defect in the second act.

Paragraph 1 of Article 35-1 of Law No. 480-V provides that regulatory legal acts of central state bodies are subject to state registration with the justice authorities and that such registration is “a necessary condition of their entry into force”. Sub-paragraph 5) of paragraph 3 of the same article creates an exemption for “regulatory legal acts, the list of which is approved by the Ministry of Justice of the Republic of Kazakhstan”.

That list is approved by Order No. 408 of the Minister of Justice of 26 June 2023 (registered with the Ministry of Justice on 26 June 2023 under No. 32893; amended by Order No. 153 of the Minister of Justice of 11 February 2026, MoJ No. 37969). Paragraph 8 of that list reads: “Regulatory legal acts on the approval (determination, establishment, allocation) of quotas, limits, prices, tariffs, tariff rates, norms, standards, physical norms, amounts, bonuses, stipends, a list, volumes, including their ceiling or minimum values, and also regulatory legal acts establishing indicators having a numerical or alphabetical designation and the procedure for their application, which do not contain additional rules of law.”

The list of goods and every 2026 order on the ceiling price of a means of identification fall within that exemption. The 2023 orders on the same ceiling price still went through registration — hence the inconsistency in the formal particulars. It does not affect legal force: a registered order and an order exempt from registration remain regulatory legal acts of the same level, and a conflict between them is resolved by the date of entry into force.

⚠️ What this means in practice. A brewer or importer that worked from the Ministry-of-Justice-registered Order No. 343-НҚ during 2026 should have been marking bottles from 1 February 2026; one that worked from Order No. 199-НҚ, from 1 September 2026. The second position is the legally correct one, but the divergence is worth recording in writing — for example by a query to the Ministry of Trade and Integration — so that the date chosen can be documented if it is ever examined. Preparing that query and the underlying position is what legal and strategic consulting is for.

Motor oils and lubricants: two dates and a rewritten set of Rules

Marking of motor oils started on 1 February 2026 and was extended on 1 September 2026 to lubricating oils, lubricants and special automotive fluids — that is, from four EAEU HS codes to fourteen.

The base act is Order No. 44-н/қ of the Minister of Energy of the Republic of Kazakhstan of 30 January 2026 “On approval of the Rules on marking and traceability of motor oils”, registered with the Ministry of Justice (MoJ) on 2 February 2026 under No. 37926. The order was issued under sub-paragraph 2) of Article 7-2 of the Law and was officially published in the Reference Control Bank of Regulatory Legal Acts in electronic form on 3 February 2026.

Paragraph 4 of Order No. 44-н/қ provides that the order enters into force on expiry of sixty calendar days after the day of first official publication, with the exception of Chapter 11 of the Rules, which enters into force on 1 February 2027. Chapter 11 is the procedure for submitting data on circulation — the transmission of data on every transaction between participants, acceptance, and change of ownership of the marking code. In other words, you must mark from February 2026, but digital tracking of the movement of goods between the wholesale tiers of the chain begins in February 2027.

What Order No. 316-н/қ changed

Order No. 316-н/қ of the Minister of Energy of 24 August 2026, registered with the Ministry of Justice on 25 August 2026 under No. 39683, did not make piecemeal amendments — it rewrote the act in full.

Order No. 316-н/қ directed that “the title of the order be restated as follows: ‘On approval of the Rules on marking and traceability of certain lubricating oils, lubricants and special automotive fluids’”, that paragraph 1 of the order be restated, and that “the Rules on marking and traceability of motor oils approved by the said order be restated in accordance with the annex to this order”.

Order No. 316-н/қ was officially published on 27 August 2026 and enters into force on expiry of sixty calendar days after the day of first official publication — by calculation, on 27 October 2026.

A comparison of the two editions shows seven substantive changes:

The deadline for converting a marking code has been extended from 30 to 90 calendar days. That is the most practically significant change: under the current edition unused codes are cancelled after a month; under the new edition, after three months.

One detail is easy to miss: Order No. 316-н/қ changed the title, paragraph 1 and the text of the Rules, but did not change paragraph 4 of Order No. 44-н/қ. The deferral of Chapter 11 to 1 February 2027 therefore survives, and in the new edition Chapter 11 (“Procedure for submitting data to the digital product marking and traceability system on the circulation of marked lubricants in the Republic of Kazakhstan”, paragraphs 37–41) takes effect on that same date.

Which HS codes the extension captured

Four codes carry a double date (motor oils from 1 February 2026; other lubricants under the same codes from 1 September 2026): 2710 19 820 0 (motor oils, compressor lubricating oil, turbine lubricating oil), 3403 19 100 0, 3403 19 900 0, 3403 99 000 0.

Ten codes come in only from 1 September 2026: 2710 19 710 0 (lubricating oils and other oils for specific processing operations), 2710 19 750 0, 2710 19 840 0 (hydraulic fluids), 2710 19 860 0 (white oils, liquid paraffin), 2710 19 880 0 (gear oil and reductor oil), 2710 19 920 0 (metal-working compounds, mould-release oils, anti-corrosion oils), 2710 19 940 0 (electrical insulating oils), 2710 19 980 0 (other lubricating oils and other oils for other purposes), 3819 00 000 0 (hydraulic brake fluids and other prepared liquids for hydraulic transmission), 3820 00 000 0 (prepared anti-freezing and de-icing fluids).

The supranational basis for the extension is Decision No. 53 of the Council of the Eurasian Economic Commission of 8 July 2025 on the marking of certain lubricating oils, lubricants and special automotive fluids.

A technical note for anyone reconciling the list row by row: entry No. 41 (code 2710 19 710 0) is printed in the official text of Order No. 253-ОД as “41.4”. That is a numbering typo, not a separate sub-entry; the list has 292 rows numbered 1 to 292.

⚠️ A gap you have to close at your own risk. The duty to mark the extended group arose on 1 September 2026 under the list. The sectoral Rules that describe the procedure enter into force in their new edition only at the end of October 2026. Formally, in the interval the previous edition applies, addressed to “motor oils”. The practical conclusion for importers of anti-freeze, brake fluids and industrial oils is to treat the duty as live from 1 September 2026, applying the earlier procedure by analogy, and not to defer onboarding to the system until late October.

The ceiling price of the means of identification for this group is set at 4.7 tenge per unit excluding VAT by Order No. 29-н/қ of the Minister of Energy of 19 January 2026, which took effect on 1 February 2026. Order No. 262-н/қ of the Minister of Energy of 10 July 2026 extended the same ceiling to the whole enlarged group from 1 September 2026 without changing the figure itself.

Beer and beer beverages: three dates, kegs, and excisable status

Marking of beer and beer beverages comes in three steps by pack type: kegs from 1 February 2026, bottles from 1 September 2026, cans from 1 January 2027.

The sectoral act is Order No. 110 of the Minister of Finance of the Republic of Kazakhstan of 19 February 2026 “On approval of the Rules on marking and traceability of beer and beer beverages with means of identification”, registered with the Ministry of Justice on 20 February 2026 under No. 38018. Its number in the State Register is 222296, the place of adoption is Astana, and first official publication in the Reference Control Bank of Regulatory Legal Acts in electronic form took place on 23 February 2026.

Paragraph 3 of Order No. 110 reads: “This order shall enter into force on expiry of sixty calendar days after the day of its first official publication, with the exception of paragraphs 29, 30, 31, 32, 36, 37, 38, 39, 40, 44, 47 and 48 of the Rules, which shall enter into force on 1 January 2027.”

The deferred paragraphs are aggregation (29–32), circulation and acceptance (36–40), withdrawal from circulation on grounds other than retail sale (44), and re-introduction into circulation (47, 48). So from spring 2026 marking, product registration and withdrawal at the till are live, while full digital traceability along the chain starts on 1 January 2027 — at the same time as the marking of cans.

One caveat matters here. Order No. 343-НҚ, which remains in force in parallel, places bottled beer at 1 February 2026 rather than 1 September 2026. Which act governs, and why, is analysed above in the section on the two lists; the correct reference point is Order No. 199-НҚ as restated by Order No. 253-ОД.

The list rows for beer cover four codes: 2202 91 000 0 (non-alcoholic beer), 2203 00 010 0 (malt beer in containers of 10 litres or less, in bottles), 2203 00 090 0 (malt beer in containers of 10 litres or less, other) and 2203 00 100 0 (malt beer in containers of more than 10 litres). Goods under that last code are in kegs by definition, and in the list the code carries only one date: 1 February 2026.

Paragraph 5 of the Rules deals with stock on hand: “Unmarked beer and beer beverages manufactured before the date of introduction of mandatory marking of beer and beer beverages included in the List of Goods … shall be sold by participants in circulation within 1 (one) calendar year.” One year to sell through, and not a day more.

Registering the product in the system requires 29 mandatory fields (paragraph 14 of the Rules), and the set is highly sector-specific: alcohol by volume as a percentage, whether the product is pasteurised, the type of filtration, whether it is flavoured, sparkling or carbonated, packaging characteristics, packaging material, a photograph of the pack, the market circulation mark, the conformity mark, and — a practical curiosity — the “maximum period for selling beer in a keg after it is connected to beer-dispensing equipment”.

The deadline to convert a marking code into a means of identification for beer is 365 calendar days(paragraph 25 of the Rules). That is one of the two longest periods: the Rules on food supplements allow one year for the same step. Codes for which the application data are not transmitted within that period are cancelled.

The structure of the beer marking code differs from the other groups. Paragraph 18 of the Rules describes three data groups, not four: application identifier “01” with a GTIN of fourteen digits, identifier “21” with an individual pack serial number of seven characters, and identifier “93” with a verification code of four characters. The string opens with the GS1 DataMatrix FNC1 symbology flag (ASCII 232).

The means of identification is applied to the consumer pack or the keg, or to the closure of either (paragraph 16). Application to parts of the pack or keg that can be detached without damage is not permitted.

Retail mechanics are described in detail. Paragraph 41 requires scanning of the means of identification by devices paired with a cash register registered under Order No. 626 of the Minister of Finance of 24 October 2025 “On certain matters relating to the use of cash registers” (MoJ No. 37238). Paragraph 42 lists the five data items that the fiscal data operator transmits to the system in real time for every unit sold: the seller’s individual or business identification number, the cash register’s registration number, the fiscal document details (receipt number and date), the date and price of sale, and the product identification code.

The key difference between beer and the other three groups is excisable status. Beer is a brewing product and therefore excisable, which brings Article 283 of the Code of the Republic of Kazakhstan on Administrative Offences (the “Administrative Code”) into play. For motor oils, food supplements and light-industry goods there is no equivalent offence in the Code. That is the subject of a separate section below.

The ceiling price of the means of identification for beer is set at 3.06 tenge per unit excluding VAT by Order No. 16 of the Minister of Finance of 9 January 2026, which took effect on 1 February 2026 and was agreed with the Ministry of Trade and Integration.

Food supplements: the tightest regime on deadlines

Marking of biologically active food supplements started on 1 September 2026 and applies to supplements manufactured from that date and holding a valid certificate of state registration.

The sectoral act is Order No. 86 of the Minister of Health of the Republic of Kazakhstan of 3 August 2026 “On approval of the Rules on marking and traceability of biologically active food supplements”, registered with the Ministry of Justice on 4 August 2026 under No. 39487. The order was agreed with the Ministry of Finance, the Ministry of Trade and Integration and the Ministry of National Economy, signed by Minister A. Alnazarova, and officially published on 10 August 2026.

Paragraph 4 of Order No. 86 has two limbs. First: the order enters into force on expiry of sixty calendar days after the day of first official publication — by calculation, on 10 October 2026. Second: “It is established that paragraphs 31, 32, 33, 34, 35, 36, 37, 41, 42, 43, 44, 45, 46, 47, 48, 51, 54 and 55 of the Rules shall apply to biologically active food supplements manufactured from 1 March 2027.”

Note the drafting technique: the deferral is tied not to a calendar date of application but to the date of manufacture. The provisions on aggregation, circulation, acceptance, internal movement between sites and re-introduction into circulation apply only to supplements manufactured from 1 March 2027. They do not apply at all to a product made on 28 February 2027, for the whole of its shelf life.

Three cumulative conditions

The list row for food supplements reads: “From 1 September 2026, mandatory marking in respect of biologically active food supplements manufactured from 1 September 2026, holding a valid certificate of state registration as biologically active food supplements in accordance with the legislation of the Republic of Kazakhstan and the Eurasian Economic Union.”

There are three conditions and they are cumulative: the product is a food supplement; it was manufactured from 1 September 2026; it holds a valid certificate of state registration. If any one fails, no duty to mark arises.

That is exactly why the list contains 56 EAEU HS codes for food supplements (entries Nos. 86–141), many of which at first glance have nothing to do with supplements: 1204 00 900 0, 1208 90 000 0, 1210 20 900 0, 1211 90 860 8, 1212 21 000 0, 1212 99 950 9, 1302 19 900 0, 1302 20, 1504 10 100 0, 1504 20, 1515 11 000 0, 1515 19 900 0, 1515 90 690 0, 1515 90 890 0, 1516 10, 1517 90 990 0, 1602 90 990 9, 1603 00 100 0, 1702 30 500 0, 1702 40 900 0, 1702 60 950 0, 1702 90 950 0, 1704 90 550 0, 1704 90 710 0, 1704 90 820 0, 1806 31 000 0, 1806 32, 1806 90 310 0, 1806 90 700 0, 1806 90 900 0, 1901 90 980 0, 1904 10 900 0, 2101 12 920 1, 2102 20 110 0, 2106 10 800 0, 2106 90 580 0, 2106 90 930 0, 2106 90 980 1, 2106 90 980 3, 2106 90 980 8, 2202 99 180 0, 2202 99 910 0, 2922 41 000 0, 2922 42 000 0, 2922 49 850 0, 2923 20 000 0, 2923 90 000 9, 2925 29 000 0, 2936, 3001 20, 3002 49 000 1, 3002 90 300 0, 3502 90 700 0, 3503 00, 3802 10 000 0, 3913 10 000 0.

Chocolate under code 1806 32 is marked only if it is registered as a food supplement. An ordinary chocolate bar under the same code falls outside the regime — until 1 September 2028, when the marking of food products begins.

What sets the food-supplement regime apart

Paragraph 6 of the Rules deals with stock on hand more gently than any of the other three acts do: unmarked supplements manufactured before the date of introduction of mandatory marking may be sold until the expiry of their shelf life. Not a year, as for beer, but the whole shelf life. Moreover, a participant may mark such supplements voluntarily — and the Rules then apply to them in full.

Registering a food supplement requires 33 mandatory fields (paragraph 15) — more than any of the other three groups. Among them: the certificate of state registration, the dosage form, the number of servings in the consumer pack, the field of application, the method of use, whether the raw material is subject to veterinary supervision, and the name, legal address and country of the production site.

Sub-paragraph 4) of paragraph 16 creates an automatic cross-check against the supranational register.Registration is refused if “the data submitted on the certificate of state registration of the supplement do not correspond to the data contained in the Unified Register of Certificates of State Registration published on the Portal of Common Information Resources and Open Data of the EAEU”. A one-letter discrepancy in the name between the certificate and the product card blocks code issuance.

The deadline to convert a marking code is one year (paragraph 27). The Rules also provide a correction mechanism: if inaccurate data on batch or lot number or on shelf life are identified, the participant makes corrections through the personal account — but only before the first change of owner.

The marking code for food supplements has four data groups (paragraph 20): “01” with a GTIN of fourteen digits; “21” with an individual serial number of thirteen characters, the first of which is the member-state identifier, which for Kazakhstan is the digit “3”; “91” with a four-character code; and “92” with a code of forty-four characters.

Circulation deadlines for food supplements are the tightest of all. Paragraph 43: data on circulation are entered no later than one working day from the date of sale or movement. Paragraph 44: acceptance is effected by confirming the data within one working day from the date of actual delivery and before any further operations. For comparison, beer, lubricants and light-industry goods allow fifteen working days for acceptance.

Paragraph 45 introduces a discrepancy notice. If discrepancies are found on acceptance, the recipient issues a notice to the sender, the earlier circulation data are cancelled, and fresh data are created. The sender may withdraw circulation data within twenty calendar days of registration, but only before the recipient confirms them.

Paragraph 42 introduces the concept of a place of business (in Russian: место осуществления деятельности, МОД). A participant with divisions or branches (retail outlets) under a single business or individual identification number creates a separate place of business in the system for each, with a mandatory role assignment by activity type. Transfers between places of business under one identification number are documented as internal circulation data (paragraph 48).

Paragraph 39 introduces an import notice. On acceptance of imported supplements into a warehouse in Kazakhstan, the importer generates an import notice and submits it to the system to obtain a registration number, and must state either the details of the import document for goods imported from EAEU member states or the details of the customs declaration for imports from third countries.

The ceiling price of the means of identification for food supplements is set at 2.68 tenge per unit excluding VAT by Order No. 74 of the Minister of Health of 10 July 2026, which took effect on 1 September 2026. That is the lowest ceiling of the four groups.

Light-industry goods: three waves, commission agents and stock on hand

Marking of light-industry goods comes in three waves: from 1 December 2026, from 1 March 2027 and from 1 October 2027.

The sectoral act is very recent: Order No. 450 of the acting Minister of Industry and Construction of the Republic of Kazakhstan of 10 September 2026 “On approval of the rules on marking and traceability of light-industry goods with means of identification”, registered with the Ministry of Justice on 10 September 2026 under No. 39858. It was signed by R. Isakulov and officially published on 14 September 2026.

Paragraph 4 of Order No. 450 provides that the order “shall enter into force on expiry of sixty calendar days after the day of its first official publication, with the exception of paragraphs 29, 30, 31, 32, 36, 37, 38, 39, 40, 43, 46 and 47 of the Rules approved by this order, which shall enter into force on 1 October 2027.” The calculated date of general entry into force is 14 November 2026 — two and a half weeks before the first wave starts.

The paragraphs deferred to 1 October 2027 are the same four blocks as in the other groups: aggregation, circulation and acceptance, withdrawal from circulation outside retail, and re-introduction into circulation. The date coincides with the third marking wave.

Three waves by EAEU HS code

Wave one, from 1 December 2026 (10 entries): 4203 10 000 (articles of apparel and clothing accessories of leather or composition leather), 4304 00 000 0 (artificial fur and articles thereof), 6113 00, 6210, 6211 20 000 0 (ski suits), 6211 32, 6211 39 000 0, 6211 42, 6211 49 000, 6302 (bed linen, table linen, toilet linen and kitchen linen).

Wave two, from 1 March 2027 (10 entries): 6106 (women’s or girls’ knitted blouses), 6110 (jerseys, pullovers, cardigans, waistcoats), 6201 and 6202 (overcoats, car-coats, capes, cloaks, anoraks, wind-cheaters and similar articles), 6205 (men’s or boys’ shirts), 6206 (women’s or girls’ blouses), 6211 33, 6211 43, 6214 (shawls, scarves, mufflers, mantillas, veils), 6215 (ties, bow ties and cravats).

Wave three, from 1 October 2027 (11 entries): 6101, 6102 (knitted overcoats and jackets), 6103 and 6104 (knitted suits, ensembles, jackets, blazers, trousers), 6105 (men’s or boys’ knitted shirts), 6112 11 000 0, 6112 12 000 0, 6112 19 000 0 and 6112 20 000 0 (track suits and ski suits), 6203 and 6204 (non-knitted suits, ensembles, dresses, skirts, trousers).

The date wording is identical in all thirty-one rows: “mandatory marking in respect of light-industry goods imported into the Republic of Kazakhstan or manufactured on the territory of the Republic of Kazakhstan”. Unlike the rows for beer, oils and food supplements, these rows make no reference to the date of manufacture.

Commission agents and marketplaces

Paragraph 4 of the Rules extends the duty to mark to the commission agent. In terms: the commission agent “shall ensure the marking of light-industry goods accepted for sale under a mandate or commission agreement concluded in accordance with the civil legislation of the Republic of Kazakhstan before they are displayed at the point of sale or when they are displayed at the point of sale, when samples of them are demonstrated, or when information about them is provided at the point of sale”.

This is the broadest construction of the four acts. It captures consignment stores, showrooms operating on an agency model, and any arrangement in which the goods do not belong to the seller. The trigger is not the sale but display, demonstration of samples or provision of information about the goods at the point of sale.

The same paragraph also places the duty to ensure marking on importation not only on the importer but on the authorised economic operator.

Stock on hand and re-application

Paragraph 4 of the Rules sets a hard deadline for stock on hand: “A participant in the circulation of light-industry goods, including a commission agent, shall ensure the marking of stock of light-industry goods with means of identification no later than 1 January 2028.”

A simplified data set applies to stock. Paragraph 14 requires only four fields: full product name, model or article number, type of article, and colour of the article. Ordinary registration (paragraph 13) requires nineteen fields, including colour, size, model, age category for position 6302, target gender, material type, raw-material composition and the individual serial number of the unit.

Paragraph 4 also requires re-application of the means of identification if it is lost or damaged — including on goods offered for sale after a consumer return and on goods held under commission or mandate agreements.

Technical features

The means of identification is applied not only to the pack but to the product itself or to the product tag(paragraph 16). This matters: clothing often has no consumer packaging at all.

The deadline to convert a marking code is 60 calendar days (paragraph 25).

The marking code has four groups (paragraph 18): “01” with a GTIN of fourteen digits; “21” with an individual serial number of thirteen characters, the first of which is the identifier of the issuing country, which for Kazakhstan is “3”; “91” with a four-character verification key; and “92” with a forty-four-character verification code.

The transport packaging identification code is supplied as a GS1-128 linear barcode under GOST ISO/IEC 15417-2013 with a unique SSCC identifier and application identifier AI = ‘00’ (paragraph 19).

Paragraph 31 sets a deadline that does not appear in the other Rules: when marked packs are repacked into another group or transport pack, aggregation data must be submitted “no later than 1 (one) working day from the day of the actual repacking of the goods”.

The terminology of the light-industry Rules is more heavily transliterated than the others: GTIN appears as ГНТЕ, ASCII as АСКОИ, DataMatrix as ДатаМатрикс and GS1 as ГС1. It is disorienting on the page, but the substance is the same set of international standards.

The ceiling price of the means of identification is set at 3.14 tenge per unit excluding VAT by Order No. 381 of the Minister of Industry and Construction of 30 July 2026. The order was officially published on 6 August 2026 and enters into force on expiry of ten calendar days after the day of first official publication — by calculation, on 17 August 2026.

Comparing the four regimes: where the Rules diverge

The four sectoral acts follow a common template but diverge on ten practically significant parameters,and those divergences drive the configuration of accounting systems.

Three conclusions follow.

First, there is no single “Kazakhstan marking regime”. There are four regimes written by four ministries, and a system configuration that works for beer will not work for food supplements.

Second, the tightest regime is food supplements, and not because of code pricing but because of the one working day for acceptance. A supplements distributor must confirm receipt in the system effectively on the day of delivery, or further operations with the goods are blocked.

Third, the widest exposure is in light industry, because the duty extends to commission agents and to stock on hand, and because the code goes on the product or the tag rather than on packaging.

How marking interacts with tax accounting — issuing electronic invoices, movement through the Virtual Warehouse, and reconciling item descriptions — is covered in a separate UPPERSETUP analysis: E-Invoices and the Virtual Warehouse in Kazakhstan in 2026: Order No. 629, Biometrics on Issuance and the New Deadlines.

The National Product Catalogue, the identification code, and what NTIN actually means

The National Product Catalogue is defined by sub-paragraph 10) of paragraph 2 of the Rules on its maintenance as “a digital object of the ‘digital government’, being the national register of product data and the single source of product nomenclature, mandatory for use as a product reference book in trading activity”.

The Catalogue and the marking system are different objects served by the same operator. The Catalogue holds the product card and its identification code; the marking system holds the codes of individual units and the history of their movement.

The legal term for the product code in the Catalogue is “identification code”. Sub-paragraph 6) of paragraph 2 of the Rules defines it as “a unique sequence of characters in machine-readable form, presented as a barcode, assigned to types of goods and contained in the National Product Catalogue for the purpose of their unambiguous identification in trading activity”.

Where the abbreviation NTIN actually lives

A full-text search of the Adilet regulatory database for the string “NTIN” returns no exact matches in the acts governing marking. The single occurrence of the abbreviation in a Kazakhstani regulatory legal act is in the Trade Policy Concept of the Republic of Kazakhstan to 2030, and it appears in the section on foreign experience describing practice in the United States: “Considerable attention is also paid to digital product marking, in particular to the use of GTIN and NTIN for tracking goods, especially in pharmaceuticals, food and consumer goods.”

The conclusion that matters for legal precision: NTIN is not a term of Kazakhstani law but the working name that the Single Operator and the market use for the identification code.

The operator gives the definition itself in the National Product Catalogue section of its business portal: “NTIN (National Trade Item Number) is a national product code limited in application to a particular territory.” It is assigned where a GTIN is absent, in accordance with standard ST RK 3833-2023, and obtaining NTIN codes on product registration in the Catalogue is free of charge. By way of contrast, the same source describes GTIN as “an international product number assigned by the GS1 organisation”.

The practical logic is this. A manufacturer or importer that is a member of GS1 Kazakhstan uses a GTIN. One that is not gets an NTIN through the National Product Catalogue and pays no GS1 membership fee. Paragraph 28 of the Catalogue Rules describes the reverse transition: “Where a domestic product registered in the National Product Catalogue is intended for export, the manufacturer shall amend the product data in the National Product Catalogue to reflect the GTIN obtained.” In other words, an NTIN suffices for the domestic market while export requires a GTIN.

An important caveat: the sectoral Rules on all four groups require a GTIN on product registration in the marking system, and the grounds for refusal expressly cover situations where the GTIN “according to the GS1 – Kazakhstan digital resource may not be used” by the participant or “does not exist”. Formally, NTIN does not appear in the text of any of the sectoral Rules. This point is worth confirming with the operator for your specific product group.

Who does what in the Catalogue

The Catalogue Rules divide roles between two different operators, and this is a second source of confusion.

The Single Operator of product marking and traceability (Kazakhtelecom) collects data on goods manufactured and in circulation before 1 January 2026, registers new product cards, maintains data accuracy, moderates (verifies) product data, organises technical support (paragraph 9), assigns the unified name and identification code on completion of moderation (paragraphs 20, 22, 23), and moves product cards to archived status (paragraph 13).

The single operator in the field of public procurement — a different entity from the Single Operator of marking — ensures uninterrupted functioning of the Catalogue (paragraph 7 as amended by Order No. 153-НҚ), access for trading entities to the data (paragraph 10), the service for checking whether a product is registered (paragraph 12), and the support and development of the Catalogue (paragraph 11).

Moderation deadlines differ by intended use (paragraph 20): three working days for use of the product in trade, ten working days for use in regulated public procurement. The same periods are allowed for remedying comments (paragraph 22). A refusal is appealed under Article 91 of the Administrative Procedure and Process Code of the Republic of Kazakhstan (paragraph 23).

Paragraph 19 contains a detail that is rare in regulatory acts: before submitting an application for moderation, the trading entity “carries out a preliminary check of the application using the artificial intelligence built into the National Product Catalogue”.

Two prohibitions matter when managing an assortment. Paragraph 25: “It is not permitted to assign two or more identification codes to a single product at the same time.” Paragraph 27: changes affecting the composition or characteristics that influence the quality or safety of the product require fresh registration with a new identification code. Cosmetic changes — name, pack design, image, spelling errors — are entered into the existing card (paragraph 26).

Foreign manufacturers register through a representative: paragraph 16 requires the application to be filed by an individual or legal entity of the Republic of Kazakhstan holding a notarised power of attorney from the foreign manufacturer.

Catalogue duties sit in the statute itself

This is not a subordinate recommendation. Sub-paragraph 9-1) of paragraph 1 of Article 31 of the Law obliges domestic trade entities (субъекты внутренней торговли) “when manufacturing or importing goods, to register them in the National Product Catalogue before effecting a sale”. Sub-paragraph 9-2) requires them “in retail and wholesale trade, to sell goods only where data on the goods are present in the National Product Catalogue”. Paragraph 4 of Article 32 casts it as a requirement to the goods themselves: “Goods must be classified according to the general classifier of goods, works and services and must have a unified name and an identification code in accordance with the National Product Catalogue.”

The scale of the task is indicated in the Trade Policy Concept to 2030: “The classification of more than 10 million goods will be coordinated and a procurement planning system based on that classifier will be launched.” The Concept’s action plan contains the item “Introduction of a unified catalogue format — launch of the National Product Catalogue — 2026 — Ministry of Trade and Integration”.

Companies newly entering the Kazakhstani market and planning to import should map Catalogue requirements onto their corporate item master in advance; questions of corporate structure and registration are covered in LLP (TOO) in Kazakhstan for Foreigners 2026: Registration, Visa, Taxes, and AIFC Comparison.

What a marking code costs

The ceiling price of a control (identification) mark and of a means of identification is a maximum set by the relevant ministry, not a tariff that business pays.

The legal basis is sub-paragraph 7) of Article 7-2 of the Law: sectoral authorised bodies “determine the ceiling price of the control (identification) mark and of the means of identification used in the marking of goods, in agreement with the coordinating body in the field of product marking and traceability and the National Chamber of Entrepreneurs of the Republic of Kazakhstan”.

The actual price is set by contract with the Single Operator and may not exceed the ceiling. VAT is charged on top.

Note the saiga derivatives: 911 tenge per unit is not a typographical error but a reflection of how few such items there are and how tightly they are controlled. For every mass-market group the ceiling sits between 2.40 and 4.7 tenge.

The payment trigger is the same in all four acts: the code supply service is paid for before the data on application of the means of identification are entered into the system, under a contract with the operator. The service is treated as rendered at the moment the application data are registered in the system.

Simple arithmetic for budgeting. A batch of 100,000 bottles of beer: 100,000 × 3.06 = 306,000 tenge excluding VAT. A batch of 50,000 packs of food supplements: 50,000 × 2.68 = 134,000 tenge excluding VAT. A batch of 20,000 canisters of oil: 20,000 × 4.7 = 94,000 tenge excluding VAT. A collection of 30,000 garments: 30,000 × 3.14 = 94,200 tenge excluding VAT.

That is the cost of codes alone. It excludes printing and scanning equipment, accounting-system integration, the contract with a fiscal data operator, and the labour of registering the item master. For small business entities, sub-paragraph 6) of paragraph 2 of Article 7-4 of the Law provides for the operator to make code-printing equipment available on lease, financial lease or other financial terms.

How the marking code is built: DataMatrix, GS1 and data groups

A marking code, as the sectoral Rules define it, is a unique sequence of characters consisting of the product identification code and a verification code, generated by the Single Operator. A means of identification is that same code applied to the pack as a two-dimensional DataMatrix barcode.

The distinction is practical. The marking code exists digitally inside the system. The means of identification exists physically on the pack. Between receiving the first and applying the second, a participant has a window running from 30 calendar days (motor oils, under the edition that applies until late October 2026) to one year (food supplements), depending on the group.

The identification code is the first two data groups: the GTIN plus the individual serial number. The verification code is the cryptographic part that allows a counterfeit to be detected.

All four acts require the same technical baseline: printing using the DataMatrix ECC200 error-correction method and ASCII encoding. On the definition written into the Rules on lubricants themselves, DataMatrix ECC200 “makes it possible to restore the entire sequence of encoded information where the code contains up to 30 per cent damage” and “has an error rate of less than 1 in 10 million scanned symbols”.

The robustness requirement is identical in all four acts: the probability of forging a means of identification by guessing must be less than 1 in 10,000.

The size of the means of identification is determined by the participant, provided the code remains machine-readable.

The structure of the data groups differs between product groups:

The terminating character for group “21” in every act is the special separator with code 29 in the ASCII table.

Transport packaging is marked separately. The transport packaging identification code is supplied as a GS1-128 linear barcode with a unique SSCC (Serial Shipping Container Code) identifier and application identifier AI = ‘00’. The Rules on beer and food supplements allow an alternative: a two-dimensional DataMatrix code.

Transmitting data on a transport or group pack is treated as equivalent to transmitting data on every unit inside it. This rule appears in all four acts and is the practical point of aggregation: there is no need to scan every bottle when shipping a pallet.

The Rules on food supplements describe aggregation in more detail than the others. Paragraph 31 distinguishes two levels of nesting: first-level aggregation combines primary and secondary packs into a transport pack; second-level aggregation combines transport packs into a higher-level transport pack. Paragraph 35 describes automatic disaggregation: if a participant has transmitted data on the circulation or withdrawal of all consumer packs that were inside a transport pack, the system automatically registers the disaggregation of that transport pack. If only part is withdrawn, the system automatically registers a new composition of the transport pack while retaining the aggregation code.

The step-by-step onboarding algorithm

Onboarding a participant into the marking system has nine steps, and the sequence is the same for all four product groups.

Step 1. Establish whether your product is on the list. Match both the EAEU HS code and the product name against the rows of the operative edition of the list — the annex to Order No. 253-ОД of 4 September 2026. Remember that the code alone is not the answer; the name carries equal weight. Check the exemptions in Article 8 of the EAEU Agreement as well.

Step 2. Establish your date. It depends not only on the group but on pack type (beer), on the product name within a single code (lubricants), on the presence of a state registration certificate (food supplements) and on the wave (light industry). Separately establish the date from which the circulation provisions begin to apply.

Step 3. Obtain an electronic digital signature. An electronic digital signature is the first of the conditions for operating in the system. Without it neither participant registration nor product registration is possible.

Step 4. Register the product in the National Product Catalogue. This is required by sub-paragraph 9-1) of paragraph 1 of Article 31 of the Law: a manufacturer or importer registers the product in the Catalogue before effecting a sale. Moderation takes three working days for trade use. A foreign manufacturer registers through a representative holding a notarised power of attorney.

Step 5. Register as a participant in circulation in the marking system. The operator carries out registration on the basis of accurate data submitted electronically. Under the Rules on lubricants the operator, within 24 hours, sends registration information to the email address given on registration, enters the participant in the register and grants access to the personal account. Designate the persons authorised to submit and request data on your behalf.

Step 6. Register the product in the marking system. The data set differs: 15 fields for lubricants, 29 for beer, 33 for food supplements, 19 for light-industry goods. Inclusion in the product register takes three working days. The grounds for refusal coincide across the acts: a product with that GTIN is already registered; the GTIN may not be used by the applicant according to GS1 Kazakhstan; the GTIN does not exist according to GS1. For food supplements a fourth ground is added — a mismatch between the state registration certificate data and the EAEU Unified Register.

Step 7. Prepare the technical infrastructure. A hardware and software complex connected to the system over communication channels provides automated data transmission. Where it is absent or not integrated, data are submitted through the personal account. Retail additionally needs a cash register with data recording and transmission functionality, a paired scanning device, a contract with a fiscal data operator, and a check that the scanners can read DataMatrix.

Step 8. Request marking codes and apply the means of identification. Within four hours of the request being registered the operator issues the codes, enters the identification codes in the register of means of identification and provides the participant with data on the codes issued. A refusal is likewise issued within four hours. Then comes conversion of the codes into means of identification and transmission of the application data within the period set for the group, failing which the codes are cancelled. The service must be paid for before the application data are transmitted.

Step 9. Configure introduction into circulation, circulation and withdrawal. Introduction into circulation on domestic manufacture occurs on transmission of the code application data; on import, on entry of the import data. Circulation means transmitting data on every change of owner and confirming acceptance. Withdrawal in retail runs through the till and the fiscal data operator; outside retail it is a separate submission within three working days.

All four acts provide for a fallback mode. Where the operator’s website confirms that data cannot be entered because of technical errors in the system, data are prepared on paper. Once the errors are resolved they are entered into the system within one working day of resolution, but no later than the day the goods are transferred to third parties.

If your corporate structure, import model or marketplace arrangements need checking before you start, begin with a legal diagnostic: legal and strategic consulting, and close the accounting and reporting side through accounting support for companies.

What happens at the till: cash registers, fiscal data operators and withdrawal

Withdrawal from circulation is the recording in the system of the fact that a specific unit of goods has left the supply chain: sold to an individual for personal consumption through a till, seized, confiscated, disposed of, spoiled, destroyed or irrecoverably lost.

The retail duty sits in the statute. Sub-paragraph 2-3) of paragraph 1 of Article 31 requires trading entities, “in retail sale of goods to which means of identification have been applied … to record transactions through cash registers with data recording and transmission functionality by reading the means of identification”.

The technical anchor is Order No. 626 of the Minister of Finance of the Republic of Kazakhstan of 24 October 2025 “On certain matters relating to the use of cash registers” (registered in the Register of State Registration of Regulatory Legal Acts under No. 37238). It is cited by the Rules on beer (paragraph 41), food supplements (paragraph 49), light-industry goods (paragraph 41) and the new edition of the Rules on lubricants.

⚠️ An outdated cross-reference inside a live act. In the edition of the Rules on motor oils that applies until Order No. 316-н/қ takes effect, the definition of “withdrawal from circulation” (sub-paragraph 8) of paragraph 2) cites Order No. 208 of the Minister of Finance of 16 February 2018 (MoJ No. 16508), while paragraph 41 of the same edition already cites Order No. 626. The internal contradiction is cured only by the new edition. In practice, follow Order No. 626.

The data flow works like this. The cashier scans the DataMatrix. The identification code data are included in the fiscal document “cash receipt”. The fiscal data operator transmits the data to the marking system. Under the Rules on beer, transmission is “in real time” and covers five items: the seller’s individual or business identification number, the cash register’s registration number, the receipt number and date, the date and price of sale, and the product identification code.

Consumer returns are handled in reverse. The participant re-introduces the goods into circulation for further sale and sends the fiscal data operator information on every restored unit for onward transmission to the system. The Rules on lubricants additionally require the cash-register return procedure to be performed in accordance with the technical requirements of Order No. 626. If the means of identification is undamaged on return, the goods are not re-marked.

Withdrawal from circulation on grounds other than retail sale is documented separately: the participant submits information to the system stating the reason no later than three working days following the day of withdrawal.

A separate rule applies to corporate buyers. The Rules on lubricants expressly oblige legal entities and individual entrepreneurs acquiring goods for purposes unconnected with onward sale to accept the goods and to submit withdrawal information to the system within no more than three working days. That means a vehicle fleet buying oil for its own use also becomes part of the process.

The Rules on lubricants (paragraph 58 of the earlier edition), on beer (paragraph 7) and on light-industry goods (paragraph 6) provide for a free mobile application that the operator must develop and publish on the internet for open use. The application supports reading the means of identification, obtaining system data on the product being checked, and user reporting of possible breaches. The Rules on food supplements contain no such provision.

Access to system data is restricted. Information is provided to a participant in respect of its own transactions, to authorised state bodies for the performance of their functions, to a manufacturer in respect of statistical and analytical information about the marked goods it produced, and to consumers in respect of product, manufacturer and seller characteristics. The Rules on lubricants list three categories — the manufacturer is not named separately there.

Liability: why the Administrative Code is still almost silent

Administrative liability for breaching marking requirements in Kazakhstan as at 23 September 2026 is established not for all marked goods but only for excisable goods, for sturgeon caviar, and in relation to breaches of the rules on the circulation of medicinal products.

That statement was verified by an exhaustive search of the full text of the Code of the Republic of Kazakhstan on Administrative Offences No. 235-V of 5 July 2014. The root “маркиров” (“marking”) appears in five articles of the Code: 282, 283, 398, 426 and 564. The phrase “средствами идентификации” (“with means of identification”) appears only in Article 283. The word “traceability” does not appear in the Code at all.

Article 283, “Breach of the rules on the marking (re-marking), with accounting and control marks, of alcoholic products other than bulk wine and of brewing products, and on the marking of tobacco products with means of identification” (title as amended by Law No. 137-VII of 11 July 2022):

Both parts provide for confiscation of the excisable goods that were the direct object of the offence and for revocation of the licence.

The tenge figures are calculated from the monthly calculation index (MCI) for 2026. The monthly calculation index from 1 January 2026 is 4,325 tenge — sub-paragraph 4) of Article 7 of the Law of the Republic of Kazakhstan No. 239-VIII of 8 December 2025 “On the Republican Budget for 2026–2028”.

Beer is a brewing product and therefore excisable, so Article 283 applies to it in full. It does not apply to motor oils, lubricants, food supplements or light-industry goods, which are not excisable.

What does apply to non-excisable groups

Article 284, “Breach of the procedure for using cash registers”, part 7, sub-paragraph 6-1). The list of details whose omission from a control receipt constitutes an offence expressly includes means of identification. The sanction under part 7 is a warning. Part 8: the same act committed again within a year of an administrative penalty being imposed is punishable by a fine of 20 MCI (86,500 tenge) for private notaries, private bailiffs and small business entities; 30 MCI (129,750 tenge) for medium business entities; and 40 MCI (173,000 tenge) for large business entities.

This is the operative offence for retail across all marked groups, including lubricants, food supplements and light-industry goods.

Article 193, “Breach of the legislation of the Republic of Kazakhstan on the regulation of trading activity”, does not cover marking with means of identification: its parts one to five concern failure to provide product information, improper use of a conformity document, and quoting prices other than in tenge.

The prohibition exists in the statute; the sanction does not

Paragraph 3 of Article 32 of the Law contains two separate prohibitions. Sub-paragraph 3) prohibits the sale of “excisable goods subject to marking in the prescribed manner without means of identification or accounting and control marks on them”. Sub-paragraph 3-1) prohibits the sale of “goods subject to marking with control (identification) marks or physical carriers without control (identification) marks or physical carriers on them”.

The prohibition in sub-paragraph 3-1) extends to non-excisable goods. But no corresponding sanction has been established for them in the Administrative Code.

The state itself has acknowledged this gap. The action plan of the Trade Policy Concept of the Republic of Kazakhstan to 2030 contains a measure worded as follows: “Establishment of administrative liability for the sale of goods without identification mark codes, for goods subject to mandatory marking and traceability.” The form of completion is “amendments to the Law ‘On the Regulation of Trading Activity’”, the deadline is 2026, and the responsible body is the Ministry of Trade and Integration. The body of the Concept states, in the section on improving the traceability system, that “coverage of the product basket will be expanded, and the questions of scaling the system and introducing liability for the sale of unmarked goods will be worked through”.

⚠️ How to read this gap. The absence of a dedicated article in the Administrative Code does not mean an absence of risk. First, the prohibition in paragraph 3 of Article 32 of the Law operates without a sanction: a transaction in goods prohibited from sale is vulnerable, and the goods may be withdrawn from circulation on other grounds. Second, the retail offence under Article 284 is already live. Third, liability is expressly planned for 2026, and a business that builds its model on the assumption that “no one is fining yet” will hit the problem retrospectively — because when the sanctions arrive it will have neither a registered item master nor a movement history in the system. Fourth, tax and customs consequences of unmarked circulation exist independently of the Administrative Code.

Exemptions: when you do not have to mark

The exemptions from marking requirements are set out in Article 8 of the Agreement on the marking of goods with means of identification in the Eurasian Economic Union, and all four Kazakhstani acts refer to that article: paragraph 4 of the Rules on lubricants, paragraph 2 of the Rules on beer, paragraph 2 of the Rules on food supplements and paragraph 2 of the Rules on light-industry goods.

The list of exemptions is closed and consists of fifteen categories.

Goods placed under customs procedures for export outside the customs territory of the Union. Goods under customs control during transport. Samples and specimens in the quantities needed for testing for conformity assessment, during storage and transport. Goods imported by organisers and participants of international exhibitions and fairs as samples and exhibits and not intended for sale. Foreign gratuitous (humanitarian) and international technical assistance registered in the prescribed manner. Goods bought at retail and returned by purchasers to sellers, where return documents exist, during storage and transport. Goods sold in duty-free shops. Goods held under customs control in customs control zones, including at temporary storage warehouses and customs warehouses. Goods during storage and use by their own manufacturers. Goods during storage by persons carrying on commission trade in goods received from individuals who are not individual entrepreneurs — until such goods are offered for sale, including before display at the point of sale, demonstration of samples or provision of information about them. Goods seized, arrested, confiscated or otherwise converted into state revenue, and goods subject to destruction, during storage and transport. Goods imported as goods for personal use and bought at retail by individuals, during storage, transport and use. Goods for the official use of diplomatic missions, consular posts and international organisations. Goods belonging to individuals who are not individual entrepreneurs and bought for personal use, during safekeeping and the provision of other services unconnected with sale. Goods imported on aircraft, sea and river vessels operating international routes, and in dining cars, buffet compartments and bar compartments of trains on international routes formed outside the territories of the member states.

Two exemptions are most often misread.

The commission-trade exemption is bounded by two conditions at once: the goods were received from an individual who is not an individual entrepreneur, and the exemption lasts only until the goods are offered for sale. The moment the goods are displayed at the point of sale, shown as a sample, or information about them is provided at the point of sale, the exemption stops working. That is precisely why paragraph 4 of the Rules on light-industry goods places the duty to mark on the commission agent at exactly that moment.

The exemption for “storage and use by the manufacturers of those goods” does not relieve the manufacturer of marking on transfer. The manufacturer must apply the means of identification before the first transfer of the goods, for consideration or free of charge, to a new owner. The exemption covers only in-plant storage and internal use.

Article 9 of the Agreement adds a duty for issuers: from the date marking is introduced, persons who produce, generate or sell means of identification or physical carriers must inform the competent (authorised) body of the member state electronically.

Common mistakes and why they are expensive

Mistake 1. Determining the duty from the EAEU HS code alone. The list expressly requires reliance “both on the EAEU HS code and on the name of the goods”. Code 2710 19 820 0 yields 1 February 2026 for motor oils and 1 September 2026 for other lubricants under the same code. Code 1806 32 creates a duty only if the chocolate is registered as a food supplement. The error cuts both ways: either a missed duty and unmarked circulation, or unnecessary spending on codes and process redesign.

Mistake 2. Failing to distinguish the marking date from the date the circulation provisions start. In each of the four groups part of the Rules is deferred: Chapter 11 for lubricants to 1 February 2027; twelve paragraphs for beer to 1 January 2027; eighteen paragraphs for food supplements to product manufactured from 1 March 2027; twelve paragraphs for light industry to 1 October 2027. Companies that plan integration as a single project on the marking start date overpay for functionality they will need a year later; companies that assume everything is already live build the wrong expectations about data.

Mistake 3. Reading a consolidated text instead of the amending orders themselves. The lag in consolidated texts on the Adilet portal is systemic in this area. As at 23 September 2026: the text of Order No. 199-НҚ is presented in the edition of Order No. 215-НҚ and does not reflect Order No. 253-ОД of 4 September 2026; the text of the Rules on motor oils does not reflect the new edition approved by Order No. 316-н/қ of 24 August 2026 and carries no footnote about it; the text of ceiling-price Order No. 29-н/қ does not reflect its amendment by Order No. 262-н/қ of 10 July 2026. The fix: open the amending orders themselves, not just the base act.

Mistake 4. Assuming unmarked stock can be sold off “somehow”. The regimes differ fundamentally. Beer: one calendar year from the date marking is introduced. Food supplements: until expiry of shelf life. Light-industry goods: not a sell-off at all but mandatory marking of stock no later than 1 January 2028. The Rules on lubricants do not address stock at all. A company that applies the “beer” year to clothing will be holding unsellable stock in January 2028.

Mistake 5. Missing the deadline to convert the marking code. Codes for which application data are not transmitted to the system are cancelled. The deadlines differ: 60 calendar days for light-industry goods, 90 calendar days for lubricants under the new edition (30 days under the current one), 365 calendar days for beer, one year for food supplements. Cancelled codes have been paid for but are unusable, and fresh ones must be requested.

Mistake 6. Configuring acceptance to a single regulation for all groups. Beer, lubricants and light-industry goods allow fifteen working days to confirm acceptance. Food supplements allow one working day from actual delivery and before any further operations. A distributor that processes receipts once a week will be in systematic breach for supplements and will block its own shipments.

Mistake 7. Ignoring the National Product Catalogue because “we don’t mark anything”. The duty on domestic trade entities to register a product in the Catalogue before sale (sub-paragraph 9-1) of paragraph 1 of Article 31 of the Law) and the prohibition on selling goods absent from the Catalogue (sub-paragraph 9-2)) apply to all goods, not only to marked ones. Paragraph 4 of Article 32 requires a unified name and an identification code from the Catalogue. Reconciling the item master with Catalogue requirements and with e-invoice issuance is best run as a single process — part of accounting support for companies.

Mistake 8. Confusing the “Rules of registration in the digital system” with registration in the marking system. Order No. 123-НҚ of 30 March 2023, with its near-identical title, governs the registration of landlords of trading places and QR codes at the entrance to a retail facility. Spending a week on the wrong act is a routine occurrence.

Mistake 9. Treating the absence of an Administrative Code article as permission not to mark. The retail offence under part 7, sub-paragraph 6-1) of Article 284 is already live; the prohibition in paragraph 3 of Article 32 of the Law operates regardless of any sanction; and the introduction of dedicated liability is officially planned for 2026 by the Trade Policy Concept to 2030.

Mistake 10. Assuming there is only one list of goods. Orders No. 343-НҚ and No. 199-НҚ run in parallel and diverge on bottled beer and on the 2022 cohort of medicinal products. A counterparty’s lawyer who opens the Ministry-of-Justice-registered Order No. 343-НҚ will arrive at a different date from your marking specialist who opens Order No. 253-ОД. The dispute is settled by paragraph 3 of Article 12 of the Law “On Legal Acts”, but the position is better fixed before the delivery than after it.

Mistake 11. Underestimating item-master registration. Food supplements require 33 fields and an automatic cross-check of the state registration certificate against the EAEU Unified Register; beer requires 29 fields with sector-specific characteristics; light industry requires 19 fields including colour, size and raw-material composition for every position. For an assortment of several thousand SKUs that is a project measured in weeks, not an evening’s work.

Who can implement this in-house and who needs a professional review

In-house implementation is realistic for a company with one product group, up to a few hundred SKUs, an accounting system that supports marking out of the box, a valid electronic digital signature and one or two warehouses. Such a company can follow the nine steps above and lean on the operator’s support desk.

In-house implementation will almost certainly fail if you have two or more marked groups with different acceptance deadlines and different code structures; if you work through commission agents or marketplaces; if you are an importer with several countries of origin and different customs arrangements; if you run a network of outlets that requires a separate place of business for each; or if your assortment changes more often than quarterly and every change of composition requires a new identification code.

A professional review is needed in seven situations.

First: you import goods under codes 2710 19 or 3403 and are not certain which date applies to a specific product — 1 February or 1 September 2026.

Second: you sell food supplements and the name on the state registration certificate differs from the name printed on the label.

Third: you work under a commission or mandate agreement with light-industry goods and are unsure when your duty arises.

Fourth: you hold significant unmarked stock and plan to sell it after the marking date.

Fifth: you are designing a group structure in Kazakhstan and need to establish where the participants in circulation will sit and how internal transfers will flow between them.

Sixth: you are relying on an Article 8 exemption as a basis for not marking — here the error costs more than the advice.

Seventh: you are starting operations in Kazakhstan from scratch and want accounting, taxation and marking built on one logic rather than repaired in sequence.

In the last case, start with the choice of legal form and tax regime: the available options are compared in Kazakhstan’s Special Tax Regimes 2026: Three Regimes Instead of Six and AIFC or LLP: Choosing a Jurisdiction Inside Kazakhstan in 2026. The VAT threshold and mechanics that drive the economics of importing marked goods are covered in VAT in Kazakhstan 2026: Registration, the 10,000 MCI Threshold, the 16% Rate, e-Invoices and Refunds. The wider picture of the tax reform is in Kazakhstan’s Tax System 2026: A Complete Breakdown. If marking discrepancies lead to an inspection, the dispute routes are described in Desk Control, Tax Audits and Appeals in Kazakhstan in 2026.

What we do. UPPERSETUP supports market entry into Kazakhstan end to end: from choosing the jurisdiction and registering the company through to setting up accounting, e-invoicing and marking compliance. The available solutions are set out in the catalogue of company registration solutions, and the country overview is on the Business Setup in Kazakhstan page.

Frequently asked questions

Does beer manufactured before 1 February 2026 have to be marked?

No. The list ties the duty to the date of manufacture: beer poured into kegs and manufactured from 1 February 2026, into bottles from 1 September 2026, and into cans from 1 January 2027. Paragraph 5 of the Rules on beer limits the sale of unmarked stock to one calendar year from the date mandatory marking is introduced. You must be able to evidence the manufacturing date from the pack and from your records.

From what date must anti-freeze and brake fluid be marked in Kazakhstan?

From 1 September 2026. Codes 3819 00 000 0 (hydraulic brake fluids and other prepared liquids for hydraulic transmission) and 3820 00 000 0 (prepared anti-freezing and de-icing fluids) are included in the list within the group of lubricating oils, lubricants and special automotive fluids with that date, and the duty applies to goods manufactured from 1 September 2026. The sectoral Rules in the edition expressly addressed to this group take effect later — by calculation from 27 October 2026 — but that does not move the date in the list.

Why does Kazakhstan have two lists of goods subject to marking, and which one applies?

Because Order No. 343-НҚ of the acting Minister of Trade and Integration of 27 September 2024 (84 entries) has not been repealed and, as at 23 September 2026, is in force alongside Order No. 199-НҚ of the Minister of Trade and Integration of 26 May 2026 (292 entries as restated by Order No. 253-ОД). They diverge on bottled beer: No. 343-НҚ places it at 1 February 2026, No. 253-ОД at 1 September 2026. The later act applies: paragraph 3 of Article 12 of the Law “On Legal Acts” provides that where the provisions of acts of the same level conflict, the provision of the act introduced into force later prevails.

What is NTIN and is it mandatory?

NTIN (National Trade Item Number) is a national product code assigned by the National Product Catalogue where the product has no GTIN, in accordance with standard ST RK 3833-2023. Obtaining NTIN codes on product registration in the Catalogue is free of charge. The abbreviation itself is not used as a legal term in Kazakhstani legislation: the Rules on maintaining the National Product Catalogue use the concept of “identification code”. Registration of a product in the Catalogue is mandatory for manufacturers and importers before effecting a sale, under sub-paragraph 9-1) of paragraph 1 of Article 31 of the Law “On the Regulation of Trading Activity”.

What does a marking code cost in Kazakhstan?

The ceiling prices of a means of identification excluding VAT for 2026 are: lubricants 4.7 tenge, light-industry goods 3.14 tenge, beer and beer beverages 3.06 tenge, food supplements 2.68 tenge. These are ceiling prices set by the relevant ministry under sub-paragraph 7) of Article 7-2 of the Law; the actual price is fixed by contract with the Single Operator, Kazakhtelecom, and may not exceed the ceiling. VAT is charged on top.

What is the fine for selling unmarked goods in Kazakhstan?

It depends on whether the goods are excisable. For excisable goods, including beer, part 2 of Article 283 of the Administrative Code applies: 50 MCI for individuals, 150 MCI for small business, 200 MCI for medium business and 500 MCI for large business, with confiscation of the goods and revocation of the licence. At an MCI of 4,325 tenge for 2026 that is 216,250 to 2,162,500 tenge. For non-excisable marked goods — motor oils, food supplements, light-industry goods — there is no dedicated article in the Administrative Code as at September 2026; part 7, sub-paragraph 6-1) of Article 284 applies, covering failure to show means of identification on the cash receipt (a warning; on repetition within a year, 20/30/40 MCI). Dedicated liability is planned for 2026 by the Trade Policy Concept to 2030.

Who must mark goods sold through a marketplace or a consignment store?

For light-industry goods, the commission agent. Paragraph 4 of the Rules requires the commission agent to ensure the marking of goods accepted for sale under a mandate or commission agreement before they are displayed at the point of sale, or when they are displayed, when samples are demonstrated, or when information about them is provided at the point of sale. The Article 8 exemption for commission trade applies only to goods received from individuals who are not individual entrepreneurs, and only until the goods are offered for sale.

What happens if the code application data are not transmitted on time?

The marking codes are cancelled. The deadlines are 60 calendar days for light-industry goods, 90 calendar days for lubricants under Order No. 316-н/қ (30 calendar days under the edition in force until it takes effect), 365 calendar days for beer and one year for food supplements. Payment for cancelled codes is not refunded automatically — that is a matter for the contract with the operator, so check the cancellation terms when you sign.

Do buyers who take goods other than for resale have to be registered in the system?

For lubricants, yes, in respect of withdrawal from circulation. The Rules expressly oblige legal entities and individual entrepreneurs acquiring goods for purposes unconnected with onward sale to accept the goods and submit withdrawal information to the system within no more than three working days following the day of withdrawal. This affects, for example, vehicle fleets and service stations buying oil for their own needs.

What is the difference between ИС МПТ and ЦС МПТ?

Nothing substantive. They are the same system under two names. “Information system of product marking and traceability” (ИС МПТ) is the terminology of earlier subordinate acts, including the Rules on motor oils in their January 2026 edition. “Digital system of product marking and traceability” is the term used by the Law “On the Regulation of Trading Activity”; the abbreviation ЦС МПТ was introduced by the 2026 subordinate acts — the Rules on beer, food supplements and light-industry goods. The new edition of the Rules on lubricants writes the term out in full, without an abbreviation. In the market the system runs under the Tañba brand.

Does a foreign manufacturer have to register in the National Product Catalogue?

Yes, but through a representative. Paragraph 16 of the Rules on maintaining the National Product Catalogue requires foreign manufacturers to be registered “on the basis of applications by individuals and legal entities of the Republic of Kazakhstan holding a notarised power of attorney from the foreign manufacturer for its registration in the National Product Catalogue”. In practice this role is taken by the Kazakhstani importer or a service company.

Key takeaways

In 2026 marking in Kazakhstan stopped being a niche topic for four industries and became a general requirement for the circulation of goods. The operative edition of the list — the annex to Order No. 253-ОД of the Minister of Trade and Integration of 4 September 2026 — contains 292 entries and sets dates out to May 2029.

There are, however, two lists: Order No. 343-НҚ of 27 September 2024 (84 entries) is also in force and gives a different date for bottled beer. The conflict is resolved by paragraph 3 of Article 12 of the Law “On Legal Acts” in favour of the later act — Order No. 199-НҚ as restated by Order No. 253-ОД.

There is no single regime: four ministries wrote four sets of Rules that diverge on acceptance deadlines (from one to fifteen working days), on code conversion deadlines (from 30 days to a year), on the number of data groups in the code (three or four), on serial-number length (seven or thirteen characters) and on the treatment of unmarked stock.

The duty is determined by the EAEU HS code and the product name together, and for beer, oils and food supplements also by the date of manufacture. For food supplements a third condition is added: a valid certificate of state registration.

The Rules on motor oils were rewritten in full by Order No. 316-н/қ of the Minister of Energy of 24 August 2026: the act becomes the Rules on lubricants, the code conversion deadline rises from 30 to 90 calendar days, and outdated cross-references are corrected.

The National Product Catalogue is a separate duty that does not reduce to marking: every manufacturer and importer must register goods before sale, and selling goods absent from the Catalogue is prohibited.

There is as yet no administrative liability in the Administrative Code for circulating non-excisable marked goods without means of identification, but the statutory prohibition operates, the retail offence under Article 284 is live, and the introduction of dedicated liability is officially planned for 2026.

Summary

Product marking and traceability in Kazakhstan are governed by Law of the Republic of Kazakhstan No. 544-II of 12 April 2004 “On the Regulation of Trading Activity”, the Agreement on the marking of goods with means of identification in the EAEU of 2 February 2018 (ratified by Law No. 230-VI of 1 March 2019) and sectoral ministerial orders. Joint-stock company Kazakhtelecom was designated Single Operator of marking by Government Resolution No. 95 of 3 March 2020; the system runs under the Tañba brand. The operative list of goods subject to marking contains 292 entries and was approved by Order No. 199-НҚ of the Ministry of Trade and Integration of 26 May 2026, its annexed list being restated by Order No. 215-НҚ of 30 June 2026 and then by Order No. 253-ОД of 4 September 2026. Order No. 343-НҚ of the acting Minister of Trade and Integration of 27 September 2024 (MoJ No. 35129), with a list of 84 entries that places bottled beer at 1 February 2026, remains in force in parallel; the conflict between the two lists is resolved by paragraph 3 of Article 12 of Law No. 480-V of 6 April 2016 “On Legal Acts” in favour of the act introduced into force later, namely Order No. 199-НҚ as restated by Order No. 253-ОД. Key 2026–2027 dates: motor oils from 1 February 2026; beer in kegs from 1 February 2026, in bottles from 1 September 2026, in cans from 1 January 2027; lubricating oils, lubricants and special automotive fluids (14 EAEU HS codes) from 1 September 2026; biologically active food supplements (56 codes) from 1 September 2026; light-industry goods in three waves from 1 December 2026, 1 March 2027 and 1 October 2027, with mandatory marking of stock on hand no later than 1 January 2028. The sectoral Rules are: Ministry of Energy Order No. 44-н/қ of 30 January 2026 (MoJ No. 37926), restated in full by Order No. 316-н/қ of 24 August 2026 (MoJ No. 39683); Ministry of Finance Order No. 110 of 19 February 2026 (MoJ No. 38018); Ministry of Health Order No. 86 of 3 August 2026 (MoJ No. 39487); and acting Minister of Industry and Construction Order No. 450 of 10 September 2026 (MoJ No. 39858). Ceiling prices of a means of identification excluding VAT are 4.7 tenge for lubricants, 3.14 tenge for light-industry goods, 3.06 tenge for beer and 2.68 tenge for food supplements. The means of identification is applied as a GS1 DataMatrix two-dimensional code with ECC200 error correction; the marking code has three data groups for beer and four for the other groups. Goods are registered in the National Product Catalogue, which assigns an identification code known in the market as NTIN (National Trade Item Number), issued free of charge where no GTIN exists, under standard ST RK 3833-2023. Administrative liability for circulating excisable goods without means of identification is established by Article 283 of the Administrative Code (50 to 500 MCI; at an MCI of 4,325 tenge for 2026, 216,250 to 2,162,500 tenge, with confiscation and licence revocation); for non-excisable marked goods there is no dedicated article as at September 2026, and its introduction is planned for 2026 by the Trade Policy Concept of the Republic of Kazakhstan to 2030.

Sources

Level 1 — primary sources (the basis for every figure and date)

1.       Law of the Republic of Kazakhstan No. 544-II of 12 April 2004 “On the Regulation of Trading Activity” — Adilet database, Ministry of Justice of the Republic of Kazakhstan

2.       Law of the Republic of Kazakhstan No. 230-VI of 1 March 2019 ratifying the Agreement on the marking of goods with means of identification in the Eurasian Economic Union (with the text of the Agreement of 2 February 2018)

3.       Code of the Republic of Kazakhstan on Administrative Offences No. 235-V of 5 July 2014

4.       Law of the Republic of Kazakhstan No. 239-VIII of 8 December 2025 “On the Republican Budget for 2026–2028”

5.       Government Resolution No. 95 of 3 March 2020 designating the Single Operator of product marking and traceability

6.       Government Resolution No. 31 of 2 February 2021 on certain matters of the Single Operator’s activity

7.       Government Resolution No. 1013 of 27 November 2025 approving the Trade Policy Concept of the Republic of Kazakhstan to 2030

8.       Order No. 199-НҚ of the Minister of Trade and Integration of 26 May 2026 determining the list of goods subject to marking and the date of its introduction

9.       Order No. 253-ОД of the Minister of Trade and Integration of 4 September 2026 (operative edition of the list)

10.    Order No. 343-НҚ of the acting Minister of Trade and Integration of 27 September 2024, MoJ No. 35129

11.    Government Resolution No. 568 of 10 September 2020 determining the list of goods subject to marking— repealed, cited as a historical link in the chain

12.    Government Resolution No. 588 of 31 August 2021 amending Resolution No. 568 — repealed, cited as a historical link in the chain

13.    Order No. 44-н/қ of the Minister of Energy of 30 January 2026 approving the Rules on marking and traceability of motor oils, MoJ No. 37926

14.    Order No. 316-н/қ of the Minister of Energy of 24 August 2026 (new edition of the Rules — lubricants), MoJ No. 39683

15.    Order No. 110 of the Minister of Finance of 19 February 2026 approving the Rules on marking and traceability of beer and beer beverages, MoJ No. 38018

16.    Order No. 86 of the Minister of Health of 3 August 2026 approving the Rules on marking and traceability of biologically active food supplements, MoJ No. 39487

17.    Order No. 450 of the acting Minister of Industry and Construction of 10 September 2026 approving the rules on marking and traceability of light-industry goods, MoJ No. 39858

18.    Order No. 232-НҚ of the Minister of Trade and Integration of 31 July 2025 approving the Rules on maintaining the National Product Catalogue and registering goods in it, MoJ No. 36544

19.    Order No. 284-НҚ of the Minister of Trade and Integration of 2 October 2025 (Catalogue Rules restated), MoJ No. 37044

20.    Order No. 153-НҚ of the acting Minister of Trade and Integration of 31 March 2026 amending the Catalogue Rules, MoJ No. 38285

21.    Order No. 29-н/қ of the Minister of Energy of 19 January 2026 (ceiling price — motor oils)

22.    Order No. 262-н/қ of the Minister of Energy of 10 July 2026 (ceiling price extended to lubricants)

23.    Order No. 16 of the Minister of Finance of 9 January 2026 (ceiling price — beer)

24.    Order No. 74 of the Minister of Health of 10 July 2026 (ceiling price — food supplements)

25.    Order No. 381 of the Minister of Industry and Construction of 30 July 2026 (ceiling price — light-industry goods)

26.    Order No. 41-П of the Minister of Ecology and Natural Resources of 11 March 2026 (ceiling price — saiga derivatives)

27.    Order No. 134 of the acting Minister of Health of 18 July 2023, MoJ No. 33144 (ceiling price — medicinal products)

28.    Order No. 514 of the Minister of Industry and Infrastructure Development of 14 July 2023, MoJ No. 33089 (ceiling price — footwear)

29.    Order No. 629 of the Deputy Prime Minister — Minister of Finance of 8 June 2023, MoJ No. 32743 (ceiling price — tobacco products)

30.    Order No. 927 of the Minister of Finance of 28 September 2020 approving the Rules on marking and traceability of tobacco products with means of identification (title as amended by Order No. 607 of 5 June 2023), MoJ No. 21302 of 29 September 2020

31.    Order No. 524 of the acting Minister of Industry and Construction of 4 December 2025 amending the Rules on marking of footwear

32.    Order No. 123-НҚ of the acting Deputy Prime Minister — acting Minister of Trade and Integration of 30 March 2023 approving the Rules of registration in the digital system, MoJ No. 32162

33.    Decision No. 53 of the Council of the Eurasian Economic Commission of 8 July 2025 on the marking of certain lubricating oils, lubricants and special automotive fluids

34.    Single Operator of product marking and traceability — the Tañba portal, Kazakhtelecom

35.    National Product Catalogue — Single Operator section (definitions of GTIN and NTIN, standard ST RK 3833-2023)

36.    National Product Catalogue — official web resource

37.    Law of the Republic of Kazakhstan No. 480-V of 6 April 2016 “On Legal Acts” — Article 12 (conflicts of norms), Article 35-1 (state registration)

38.    Order No. 408 of the Minister of Justice of 26 June 2023 approving the list of regulatory legal acts not subject to state registration with the justice authorities, MoJ No. 32893

Level 2 — context and cross-checking

39.    UPPERSETUP. E-Invoices and the Virtual Warehouse in Kazakhstan in 2026: Order No. 629, Biometrics on Issuance and the New Deadlines

40.    UPPERSETUP. VAT in Kazakhstan 2026: Registration, the 10,000 MCI Threshold, the 16% Rate, e-Invoices and Refunds

41.    UPPERSETUP. Kazakhstan’s Tax System 2026: A Complete Breakdown

Disclaimer

This material is informational in nature and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, obtain individual professional advice tailored to the specific situation, jurisdiction, company status and current regulatory requirements.

Currency of this material: September 2026. The status of every act cited here was checked against the Adilet database on 23 September 2026. Kazakhstan’s marking framework is moving fast: in the first nine months of 2026 the list of goods was restated twice and the Rules on motor oils were rewritten in full. Consolidated texts on the portal lag behind the amending orders, so before relying on any position stated here, open the amending orders themselves and not only the base act.