Executive Director of Jingsh Law Firm Maxim Slugin commented to Kommersant on the dispute concerning the new rules for tracking cargo using navigation seals within the Eurasian Economic Union.
By 30 July 2026, the Eurasian Economic Commission is expected to revise the list of cases in which foreign trade participants are exempt from the requirement to use navigation seals when transporting goods across the EAEU. From 31 July 2026, mandatory sealing is expected to be extended, including to the rail transportation of highly taxable goods and to road transit.
The dispute concerns the so-called “national reservation”. Under the proposed new list, the exemption from the use of navigation seals would not apply to goods entering through the Russian and Belarusian sections of the EAEU customs border and placed under the customs transit procedure in those countries.
Maxim Slugin noted that this reservation may reflect heightened scrutiny of certain import and transit routes through Russia and Belarus. At the same time, in his view, the measure has not yet been sufficiently justified in public.
In particular, he stated:
“If an Authorised Economic Operator is recognised as a person presenting a lower level of risk, any departure from the general exemption for Russia and Belarus should be supported by specific risks, statistics on violations or particular features of enforcement practice.”
Maxim Slugin also noted that the carriers’ comments on the draft are partly justified: companies operating through Russia and Belarus may find themselves in a less advantageous position than participants using other transportation routes within the EAEU.
For businesses, this means that the use of navigation seals is becoming not only a customs-control instrument, but also a factor affecting the cost, timing and selection of supply routes. Foreign trade participants should take into account in advance the possible expansion of mandatory sealing requirements and verify whether their shipments remain eligible for an exemption from the use of navigation seals.
Maxim Slugin’s full comments and the article are available at: https://www.kommersant.ru/doc/8674085
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