Mandatory Marking Requirements

By September 1, 2023, manufacturers of hand sanitizers, antibacterial lotions, hand sprays, and wet wipes were obligated to register in the “Chestny ZNAK” system and provide a description of their products in the catalogue.

This is due to the fact that starting from October 1, 2023, marking of cosmetic hand care products with stated antimicrobial activity and hand sanitizers with an identifier is mandatory in accordance with the Decree of the Government of the Russian Federation No. 870 dated May 30, 2023.

Starting from this date, manufacturers must apply the marking code onto the consumer packaging and submit this information into the “Chestny ZNAK” system.

To establish whether your products are subject to the marking requirements, the following guidance materials should be considered simultaneously:

•  TN VED [Goods Nomenclature for Foreign Economic Activities] code: 3304 99 000 0 (cosmetic products), 3808 94 800 0 (disinfectants);

•  OKPD 2 [All-Russian Classifier of Products by Type of Economic Activity] code: 20.42.15 (cosmetic products), 20.20.14.000 (disinfectants);

•  purpose: for hand hygiene;

•  stated activity: antimicrobial.

We would also like to note that in accordance with the draft decision No. 3 of the EEC Council on amendments to TR CU 009/2011 “On the Safety of Perfumery and Cosmetic Products”, the requirements of these Technical Regulations do not extend to disinfectants and antiseptics. This means that only the antibacterial activity should be specified in the name of the cosmetic product; the conformity assessment of such products is performed in the form of declaring conformity with the requirements of TR CU 009/2011.