Legal basis
The product marking system in Russia is regulated by several normative legal acts:
- Resolution of the Government of the Russian Federation No. 577 “On establishing the amount of fees for the provision of services for issuing marking codes required for the creation of identification means and for monitoring the movement of goods, as well as on the procedure for their collection”;
- Resolution of the Government of the Russian Federation No. 515 “On the system of product marking using identification marks and the traceability of the movement of goods”;
- Directive of the Government of the Russian Federation No. 792-r “On approving the list of specific goods subject to mandatory marking using identification marks”.
This list of goods requiring mandatory marking is continuously being expanded. Separate normative documents exist for each product category. A complete overview is available on the official website of the “Chestny ZNAK” system.
The practical implementation of the marking system is carried out by the operator company CRPT (Center for the Development of Advanced Technologies / Центр развития перспективных технологий).
Important legislative changes
The following regulations enter into force:
1) Expansion of the product list:
Each year, the number of product groups subject to mandatory marking in the Russian Federation is expanded. The current list is available on the website честныйзнак.рф or on our portal.
2) Refined packaging requirements:
Products must be marked with a digital marking code that can be tracked through the “Chestny ZNAK” portal.
3) Liability for non-compliance:
Missing or incorrect marking leads to fines for businesses. The circulation of unlabeled goods included in the marking programs is prohibited.
These measures enable better tracking of goods, inventory control, prevent the sale of counterfeit products, and ensure product safety on the market.
Product groups
The range of products subject to mandatory marking is continuously expanding.
Products subject to marking:
- Beer and low-alcohol beverages
- Dairy products
- Non-alcoholic beverages
- Bottled water
- Medicines
- Tobacco products
- Light industry goods
- Footwear
- Fur coats
- Non-alcoholic beer
- Vegetable oils
- Canned products
- Basic foodstuffs (dry goods)
- Motor oils
- Construction materials
- Sports nutrition
- Pharmaceutical raw materials and medicines
- Medical devices
- Perfumes and eau de toilette
- Tires
- Cameras and flash units
- Biologically active food supplements (BAA)
- Antiseptics and disinfectants
- Wheelchairs
- Seafood (caviar)
- Bicycles
- Pet food
- Veterinary medicines
- Technical rehabilitation equipment
- Cosmetics, household chemicals, and personal care products
- Children’s toys
- Confectionery
- Instant and brewable beverages
Pilot projects for marking until February 28, 2026:
- Titanium metal products (completed)
- Radio electronics
- Low-alcohol beverages
- Medical devices 2.0
- Auto parts
- Hygiene products
- Household and furnishing goods
- Fiberglass
- Printed products (completed)
- Heating equipment
- Cable products
- Pyrotechnics
- Polymer pipes
Obligations of market participants
All participants in the supply chain are involved in the implementation:- Manufacturers and importers: registration in the Chestny ZNAK system, ordering and application of Data Matrix codes.
- Wholesalers and distributors: recording and forwarding of marking data via EDI/EDO systems.
- Retailers: scanning the codes at online cash registers (ФФД 1.2) with transmission to the central database.
Technical requirements
To participate in the system, the following are required, among other things:- Electronic signature (УКЭП)
- Access to the GIS MT “Chestny ZNAK” system
- 2D scanners and online cash registers with updated software
- Labeling printers or integrated marking systems
GLN and GTIN Numbers in the EAC Declaration
In the context of the EAC Declaration, international identification numbers such as GLN (Global Location Number) and GTIN (Global Trade Item Number) are gaining increasing importance. They serve to uniquely identify companies, production sites, and products, and are relevant not only for EAC conformity assessment, but also for the mandatory product marking in the Russian “Chestny ZNAK” system.
GLN & GTIN in the “Chestny ZNAK” marking system
Since the introduction of the “Chestny ZNAK” system in 2019, the GTIN has been a central element of digital product marking. Products are marked with a Data Matrix code, the first 14 digits of which represent the GTIN code. This ensures that each product item is uniquely identified and that the supply chain can be fully traced — from import or production through to the sale to the end consumer. The legal basis includes, among others, Regulation No. 620 of 28.04.2018 and Regulation No. 792 of 26.06.2019.
The GTIN is the global product number of an item in the international GS1 database. It functions like an electronic address on the internet — a coded path to the product page. By scanning the barcode, the system participant receives extended product information.
GLN – Global Location NumberThe GLN is the Global Location Number in the GS1 database, through which information about a company can be accessed. This includes legal and postal addresses, financial data, names of directors and senior staff, details of storage facilities, and other relevant company information.
A practical overview of what GLN/GTIN are specifically needed for, how to apply for them, and how they are used in “Chestny ZNAK” (Data Matrix, first 14 digits = GTIN) can be found in our specialist article GLN and GTIN in EAC Certification and EAC Declaration.
Mandatory product groups
The obligation to use GTIN now applies to a wide range of goods: fur products, tobacco, footwear, perfumes, cameras and flash units, tires, medicines, as well as, since 2021, numerous light industry products and dairy products. Implementation is carried out gradually in accordance with the resolutions of the Ministry of Industry and Trade.
Where do companies obtain their GTIN?
In Russia, the international organization GS1 is represented by ЮНИСКАН/ГС1 РУС. Companies participating in the “Chestny ZNAK” system must become members of GS1 in order to obtain GTIN codes. The registration cost is approximately 25,000 RUB, while for companies already registered in “Chestny ZNAK” the fee is reduced to around 3,000 RUB. Further details are regulated by Order No. 877 of the Minpromtorg dated 31.05.2019.
GLN for companies and production sites
In addition to GTIN, GLN is also important. This number uniquely identifies the company as well as its production and distribution sites and is often required as a mandatory field in the EAC declaration and the “Chestny ZNAK” system. It ensures that test reports, contracts, and certificates can be assigned to a specific organization.
GS1 DataMatrix – marking code
GS1 DataMatrix is a barcode used for product marking. It allows the encoding of the keys of the GS1 system — a global, international product numbering system — and contains information about the product, such as weight, batch and serial numbers, manufacturing date, and expiration date. The barcode consists of a group of black-and-white squares arranged according to specific rules.
Structure of the GS1 DataMatrix code:
- ASCII 232 (FNC1): A special character indicating that the encoded sequence is a GS1 code. Without this character, technical devices cannot correctly recognize and process the code.
- Product code (GTIN): A 14-digit number assigned to each product described in the system.
- Serial number: A unique identification number of up to 21 characters.
- Data separator ASCII 29 (GS): Used to separate blocks of information — e.g., product data, code, serial number, etc.
- Check key: Provided by the system operator as part of the verification code.
- Electronic signature (“crypto tail”): Also provided by the system operator and consists of 88 characters (digits, uppercase and lowercase Latin letters, and special characters). It is used for cryptography and authenticity verification.
At the end of fields of variable length, separators (GS1 special characters) must be used to uniquely identify individual code blocks.
Note: The National Product Catalog is intended to serve in the future as a comprehensive directory of all goods available on the Russian market and to contain detailed product descriptions. For each individual product, a separate profile is planned, in which all accompanying and approval documents will be stored.
Fines and sanctions for non-compliance with marking regulations
Since 2025, the introduction of mandatory product marking in Russia has been accompanied by strict liability measures for companies that do not comply with the new rules.
It is important to understand the penalties and sanctions for violations if goods are not marked correctly or on time, in order to avoid additional costs.
1. Fines for manufacturers and importers since 2025
Companies that manufacture or import goods subject to mandatory marking must strictly adhere to the established deadlines and conditions. The following sanctions apply in case of violations:
- Missing labeling: If a product is not labeled within the prescribed period, a fine of 30,000 to 50,000 RUB applies for legal entities and 10,000 to 30,000 RUB for individual entrepreneurs.
- Sale of unlabeled products: The sale of goods without the required labeling is punishable by fines of 50,000 to 100,000 RUB for legal entities and 10,000 to 30,000 RUB for individual entrepreneurs.
- Sale of counterfeit products: If labeled products turn out to be counterfeit, a fine of up to 300,000 RUB applies for legal entities and up to 100,000 RUB for individual entrepreneurs. In severe cases, business activities may be temporarily suspended.
2. Penalties for discrepancies in marking data
If the data entered into the marking system does not match the actual goods, the company may be penalized:
- Incorrect or incomplete information: If there are discrepancies between the actual product data and the information recorded in the system (e.g., incorrect product code or faulty description), a fine of 20,000 to 50,000 RUB may be imposed.
3. Liability for delays in marking
Companies that do not carry out marking on time must also expect sanctions:
- Violation of marking deadlines: If a product is not assigned a code within the legal timeframe, a fine of up to 200,000 RUB for legal entities and up to 50,000 RUB for individual entrepreneurs may be imposed.
4. Suspension of goods circulation
Goods that do not comply with marking regulations may be withdrawn from circulation. This applies to cases where products are not registered in the “Chestny ZNAK” system or are identified as counterfeit.
- Suspension of goods circulation: If unlabeled or counterfeit products are detected, authorities may temporarily halt their distribution and storage until the violations are fully rectified.
5. Responsibility for incorrect marking algorithms
For certain product groups, special marking requirements apply, for example, for medicines or tobacco products. Non-compliance with the prescribed formats or coding can lead to significant fines.
- Incorrect labeling: Using a faulty code (e.g., incorrect barcode or QR code) may result in fines of 100,000 to 200,000 RUB for legal entities and 30,000 to 50,000 RUB for individual entrepreneurs.
6. Additional sanctions
In addition to fines, non-compliance with marking regulations may also have further legal and business consequences:
- Suspension of licenses: In cases of systematic violations of the marking obligation, the license or accreditation to sell certain goods (e.g., medicines) may be temporarily revoked.
- Reputational risks: Legal violations can lead to loss of trust from customers and business partners and significantly damage the company’s image.
- Seizure of goods: Products that violate marking regulations may be seized by authorities.
Recommendations for companies
1. Early Preparation:
To avoid fines and sanctions, it is important to take all necessary measures in a timely manner and prepare early for the implementation of the marking system. This includes modernizing technical equipment, training staff, and integrating the system into internal accounting processes.
2. Monitoring deadlines and requirements:
It is crucial to track the deadlines for mandatory marking of each product group and ensure that products are marked on time.
3. Verification of data compliance:
Companies should ensure the accuracy of the data entered into the system to avoid fines due to incorrect or incomplete information.
4. Integration with the “Chestny ZNAK” system:
It is necessary to register in the system via the official website in a timely manner and regularly update product information.
Compliance with marking regulations not only helps avoid sanctions but also strengthens consumer trust, improves product quality, and creates long-term competitive advantages in the market.
Our Support
Schmidt & Schmidt accompanies you through all steps: from analyzing whether your products are subject to mandatory marking, to registration in the Chestny ZNAK system, ordering and managing the codes, and finally to practical implementation in marking and integration into your document management. Through our international presence, we ensure that all processes are compliant with the law and in accordance with the requirements of the Russian authorities.
