Since almost all perfumery and a significant part of cosmetics contain ethylene alcohol, these products are considered “alcohol-containing non-food products” in Russia. This means that export of perfumery and cosmetics to Russia is subject to a special set of requirements.
What are these requirements? They are: licensing, excising and reporting.
Licensing
Companies must obtain a licence in order to manufacture, storage, transport or supply (including import or export) alcohol-containing non-food products, (article 18 of Law No. 218-FZ of 22 November 1995 on the State Regulation of Manufacture and Supply of Ethylene Alcohol as Well as of Alcoholic and Alcohol Containing products and on the Restrictions of Consumption of Alcoholic Beverages).
Products exempt from the licensing requirement
No licence is required for perfumery and cosmetic products which have undergone state registration by the Federal Consumer Rights Protection and Human Wellbeing Service (Rospotrebnadzor).
There is a list of exported perfumery and cosmetic products to which the licensing requirement does not apply. The list was approved by Decree No. 401 of 25 June 2007 (last amendment of 11 October 2012) and is provided in the below table:
|
Name of perfumery or cosmetic product |
Product code according to the Common Product Nomenclature for External Trading of the Customs Union (TN VED TS) |
Maximum size of consumer packaging (ml) |
|
Essential oils (both terpene-containing and not) |
3301 12 - 3301 29 910 0 |
25 |
|
Perfumes and eau de toilette |
3303 00 |
150 |
|
Cosmetics and make up products as well as skin care products (except medical products), including tan-protection products or tanning products; manicure and pedicure products |
3304 |
250 |
|
Hair care products |
3305 |
500 |
|
Tooth and mouth hygiene products |
3306 10 000 0 3306 90 000 0 |
300 |
|
Products used before, after and for shaving, deodorants and antiperspirants of individual purpose as well as other perfumery and cosmetic products, including perfume water.
|
3307 10 000 0 3307 20 000 0 3307 90 000 |
250 |
Excises
According to the Tax Code of Russia, alcohol-containing products with the content of alcohol exceeding 9% are subject to excise duty. This, however, excludes perfumery and cosmetics in packaging not exceeding 100 ml with the content of alcohol not exceeding 80% and/or up to 90%, provided that the packaging (a bottle or flask) is equipped with an atomizer. Perfumery and cosmetic products with the alcohol content of up to 90% and packaging size not exceeding 3 ml, are also excluded from the requirement to pay excise duty.
Reporting
Companies exporting to Russia alcohol-containing non-foods with the alcohol content exceeding 25% of the finished product volume, must keep records and submit reports (declarations) on the quantities they export to Russia.
Which customs point?
Exporters of cosmetics and perfumery to Russia should choose the right customs entry point at the Russian border. Not all customs offices are authorized to deal with products subject to excise duties and licences. The exporters must determine whether their perfumery and cosmetic products are subject to excise duty and/or licensing. If they are subject to either or both, then they may only choose the custom entry points specified in the lists adopted by Order of the Federal Customs Service of Russia No. 1144 of 1 June 2011.