Which Dietary Supplements Are Subject to Mandatory Digital Labeling in Russia in 2026?
Russia's mandatory dietary supplement labeling has expanded in three waves — October 2023, March 2025, and March 2026 — and in 2026 the key practical question for every manufacturer and importer is not just whether their product is on the list, but which wave it belongs to, because that determines when Data Matrix codes were required and how long unlabeled stock can still be sold.
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As a general rule, dietary supplements with a valid State Registration Certificate (SGR, from the Russian abbreviation) listed in the EAEU Unified Register are subject to Russia's mandatory digital labeling requirements. Certain exemptions apply depending on the product's intended use and customs procedure.
To determine compliance requirements, manufacturers and importers must account for the specific dates and legal acts that integrated their product categories into the labeling system:
October 1, 2023: Mandatory digital labeling took effect for the initial list of dietary supplements under Russian Government Decree No. 886 dated May 31, 2023.
March 1, 2025: The list of products subject to mandatory digital labeling was expanded under Russian Government Decree No. 1680 dated November 30, 2024.
March 1, 2026: The list was further expanded to include fish liver oils and their fractions, and other enzyme preparations under Russian Government Decree No. 1953 dated November 28, 2025. These categories include TN VED EAEU codes 1504 10 990 0 and 3507 90 900, together with OKPD 2 codes 10.41.12 and 20.14.64.
The exact date an item was added to the mandate dictates when Data Matrix codes must be applied and establishes the rules for selling previously manufactured or imported stock.
How to Check If a Dietary Supplement Needs Labeling in Russia?
To verify if a product requires a digital code, companies must locate its SGR in the EAEU Unified Register and match the applicable TN VED EAEU and OKPD 2 classification codes against the official list of marked products. This review should be completed before packaging is printed, Data Matrix codes are ordered, or the product is imported into Russia.
Key Checks Before Importing Dietary Supplements into Russia
- Find the SGR (State Registration Certificate) in the EAEU Unified Register and confirm its status is active.
- Verify that the SGR (State Registration Certificate) was issued specifically for a dietary supplement.
- Ensure the product name and manufacturer details match the physical goods.
- Cross-check that the composition and form align with the official registration data.
- Confirm the TN VED EAEU customs classification code and OKPD 2 product classification code are accurately determined.
- Validate that these details match the product card registered in the National Catalog.
Since mandatory labeling is directly linked to the product's registration status, we have covered the full state registration procedure, required documents, testing, and the process of obtaining an SRC in our detailed guide, “How to Register Dietary Supplements (BAA) in Russia in 2026?”
What Should I Do If a Supplement's Classification Code Is Not Listed in Russia?
In some cases, a product may hold a valid SGR as a dietary supplement, but its assigned TN VED EAEU code is missing from the active mandatory labeling list. When this occurs, the manufacturer or importer can submit a direct inquiry to the Russian «Honest Sign» («Chestny ZNAK») support team at: bio@crpt.ru. The request should include evidence confirming the product's registration status and proper classification.
Information to Include in a «Honest Sign» (Chestny Znak) Inquiry
- The product name, SGR number (State Registration Certificate), and manufacturer details.
- The currently assigned TN VED EAEU and OKPD 2 codes.
- A description of the product's composition and intended purpose.
- A copy of the SGR and official classification documents, such as a formal clarification letter from the Federal Customs Service.
Are There Exemptions for Supplement Labeling in Russia in 2026?
Mandatory labeling rules do not apply to specific categories of dietary supplements that are not intended for standard commercial sale within the Russian market. Claiming an exemption requires documentary proof; an internal company decision is not sufficient to classify a commercial batch as a marketing sample. The intended use must be supported by the quantity of goods, proper documentation, and the actual method of distribution.
Dietary Supplements Exempt from Mandatory Digital Labeling in Russia
- Products placed under customs procedures for export outside the EAEU.
- Advertising and marketing samples produced or imported into Russia strictly for non-commercial use.
- Products involved in transactions where the details constitute a state secret.
- Samples intended for laboratory testing and conformity assessments.
- Goods imported exclusively as exhibits for international trade fairs and not intended for sale.
- Items under customs transit or customs warehouse procedures.
- Foreign humanitarian aid and international technical assistance.
- Goods sold in duty-free shops.
- Supplements imported by individuals for personal use.
- Products intended for official use by diplomatic and consular missions.
For exported goods, the supply chain route determines the requirements. If the original owner exports the goods directly from the production site in sealed packaging, labeling may not be required. However, if the product is transferred between entities within Russia or placed in a local warehouse prior to export, labeling requirements depend on the specific delivery scheme.
What Is the Deadline to Sell Unmarked Supplements in Russia?
The deadline for selling unlabelled inventory is determined by two factors: the date the supplement category entered the mandatory labeling system, and the product's expiration date. Based on official clarifications, products covered by the 2023 and 2025 mandates can be sold until their expiration dates, provided they were produced or imported before the respective rules took effect. Separate transition deadlines apply to the newer categories added in 2026.
Naturally, products cannot be sold after their individual expiration dates, regardless of general transition rules.
Transition Deadlines for Selling Unmarked Dietary Supplements in Russia.
| Product Category | Production or Import Date | Deadline to Sell Without a Label |
|---|---|---|
| Supplements subject to labeling from October 1, 2023 | Produced/imported by September 30, 2023 | Until the expiration date |
| Supplements subject to labeling from March 1, 2025 | Produced/imported by February 28, 2025 | Until the expiration date |
| Fish oils & enzymes added to the list on March 1, 2026 | Produced/imported by February 28, 2026 (Shelf life up to 3 years) | August 31, 2026 |
| Fish oils & enzymes added to the list on March 1, 2026 | Produced/imported by February 28, 2026 (Shelf life over 3 years) | August 31, 2027 |
What Documents Are Needed to Sell Unmarked Supplements in Russia?
To apply the transition period rules, a company must confirm that a specific batch was produced or imported prior to the mandatory labeling date for that category. Without supporting documents, verifying the legal origin and sale of unlabelled stock is difficult during an inspection. It is recommended to account for marked and unmarked goods separately to streamline inventory management.
The required documentation must identify the product name, batch number, quantity, date of production or customs release, manufacturer, supplier, and recipient. Accepted documents include:
- Supply contracts and Universal Transfer Documents (UPDs, from the Russian abbreviation).
- Waybills and batch passports.
- Customs declarations and customs release documents.
- Documents confirming the import of products from EAEU member states.
- Production logs and detailed warehouse accounting records.
Professional Assistance with Dietary Supplement Registration in Russia and the EAEU
Accurately determining mandatory labeling requirements begins with verifying the product's registration status. Before production or import, it is essential to ensure the SGR is active, the composition data is current, and the classification codes align with the National Catalog.
Unified Center of Expertise & Certification "Quality" (LLC UCEC "Quality") is one of the market leaders in the registration of pharmaceuticals and dietary supplements in Russia and the EAEU. Our specialists guide manufacturers and importers through every stage of registration and market entry.
We can help you:
- Determine the correct state registration procedure for your supplements.
- Prepare the registration dossier.
- Organize necessary laboratory testing.
- Verify the product's composition and intended purpose.
- Obtain the State Registration Certificate (SGR).
- Review labeling layouts and packaging mock-ups.
- Submit amendments to an existing SGR.
- Prepare the required documentation for production and import.
If you are planning to register dietary supplements in Russia or other EAEU countries, contact UCEC Quality LLC for a professional consultation. We will review your documentation, outline the registration process, and help ensure your products meet all regulatory requirements for the market.
Frequently Asked Questions (FAQ)
Which dietary supplements are subject to mandatory labeling in Russia in 2026?
Dietary supplements subject to mandatory labeling in Russia in 2026 are those that hold a valid state registration certificate listed in the EAEU Unified Register and whose EAEU HS and OKPD 2 classification codes appear on the official mandatory labeling list. In 2026, products from all three expansion waves of the list must be accounted for: the initial categories covered from October 1, 2023, the additional groups added from March 1, 2025, and the newest additions — fish liver oils and their fractions, and other enzyme preparations — added from March 1, 2026. The commercial name of the product is not a reliable guide — what matters is the registration status and the classification codes.
How can I check if my dietary supplement requires mandatory labeling in Russia?
The verification must be completed before packaging is printed, codes are ordered, or the product is imported. The process follows a specific sequence: find the state registration certificate in the EAEU Unified Register and confirm it is active. Verify that it was issued specifically for a dietary supplement. Confirm the product name and manufacturer details match the physical goods. Check that the composition and release form align with the registration data. Determine the EAEU HS and OKPD 2 codes and match them against the current mandatory labeling list. Confirm the relevant details match the product card in the National Catalog. A discrepancy at any of these steps can result in automatic denial of code issuance. The experts at Unified Center of Expertise and Certification (UCEC Quality LLC) note that the most common early mistake is trying to determine whether labeling is required based on the product name alone, or by analogy with a similar product. The correct approach requires checking the registration certificate, the intended use, and the assigned classification codes at the same time.
What should I do if my dietary supplement code is not on the mandatory labeling list in Russia?
If a product holds a valid state registration certificate as a dietary supplement but its assigned EAEU HS code does not appear on the active mandatory labeling list, the manufacturer or importer can submit a formal inquiry to the Honest Sign support team for the dietary supplement product group at bio@crpt.ru. The request should include the product name, registration certificate number, manufacturer details, assigned EAEU HS and OKPD 2 codes, a description of the product's composition and intended purpose, a copy of the registration certificate, and official classification documents — for example, a formal clarification letter from the Federal Customs Service. The experts at Unified Center of Expertise and Certification (UCEC Quality LLC) recommend submitting this inquiry before ordering packaging or importing goods. An official response from the support team provides documented confirmation of the product's status, which protects the company during subsequent regulatory checks.
Are there any exemptions from mandatory dietary supplement labeling in Russia?
Yes. Mandatory labeling does not apply to dietary supplements that are not intended for standard commercial sale on the Russian market. Exempt categories include products placed under customs procedures for export outside the EAEU, advertising and marketing samples produced or imported strictly for non-commercial use, samples for laboratory testing and conformity assessments, goods imported exclusively as exhibits for international trade fairs and not intended for sale, items under customs transit or customs warehouse procedures, foreign humanitarian aid, goods in duty-free shops, supplements imported by individuals for personal use, and products for diplomatic and consular missions. Each exemption must be supported by documentation — an internal company decision alone is not sufficient to classify a commercial batch as, for example, a marketing sample.
Does the exemption for exported dietary supplements apply automatically in Russia?
No. For exported products, the supply chain route determines whether the exemption applies. If the original owner exports the goods directly from the production site in sealed packaging, labeling may not be required. However, if the product is transferred between entities within Russia or placed in a local warehouse before export, the labeling requirements depend on the specific delivery scheme. Companies planning to export dietary supplements from Russia should assess the applicability of the exemption based on the actual logistics arrangement for each specific shipment, not as a blanket assumption.
Until when can I sell unmarked dietary supplement leftovers in Russia?
The deadline for selling unlabeled inventory depends on when the supplement category entered the mandatory labeling system and the product's expiration date. For supplements covered from October 1, 2023 and March 1, 2025: products produced or imported before the respective mandatory labeling dates may be sold until their expiration date. For fish liver oils and enzyme preparations added from March 1, 2026: unlabeled products produced or imported by February 28, 2026 with a shelf life of up to three years may be sold until August 31, 2026; those with a shelf life of more than three years may be sold until August 31, 2027. Products cannot be sold after their individual expiration date regardless of the general transition deadline. From September 1, 2027, no unlabeled packages of mandatory-labeling dietary supplements should remain in circulation.
What documents do I need to sell dietary supplements without labeling in Russia?
To apply the transition period rules, the company must be able to prove that a specific batch was produced or imported before the mandatory labeling date for that category. Required documents include supply contracts and universal transfer documents, waybills and batch passports, customs declarations and customs release documents, documents confirming import from EAEU member states, and production logs and warehouse accounting records. Documents must identify the product name, batch number, quantity, date of production or customs release, manufacturer, supplier, and recipient. Without supporting documents, verifying the lawful origin and sale of unlabeled stock becomes difficult during an inspection.
Should I keep labeled and unlabeled dietary supplement stock in separate inventory in Russia?
Yes, and this is strongly recommended regardless of whether it is formally required. Maintaining separate inventory for labeled products and unlabeled stock eligible for transition-period sales significantly simplifies inventory management, makes it easier to confirm the origin and production date of each unlabeled batch during inspections, and reduces the risk of mixing labeled and unlabeled goods in a way that creates compliance questions. Each unlabeled batch should have the documentation proving its production or import date readily accessible.
Who can help with dietary supplement registration and labeling compliance in Russia and the EAEU?
If your company needs help determining whether a specific product is subject to mandatory labeling, verifying the current status of a registration certificate, checking classification codes, preparing a product card for the National Catalog, amending an existing certificate, or preparing documentation for production and import, professional support prevents the registration and documentation errors that block code issuance and delay market entry. Unified Center of Expertise and Certification (UCEC Quality LLC) is one of the market leaders in the registration of pharmaceuticals and dietary supplements in Russia and the EAEU. The company's specialists guide manufacturers and importers through every stage of registration and market entry — determining the correct registration procedure, preparing the dossier, organizing required testing, reviewing labeling and packaging mockups, and submitting amendments to existing certificates. Reach out for a consultation — and resolve documentation issues before production begins or goods arrive at the border.
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