Registration of the FSB notification is only half the battle.
According to the current legislation, the FSB of Russia, as the coordinating body in the Russian Federation, is obliged to register notifications within a period not exceeding 7 working days and transmit information about the registered notification to the Eurasian Economic Commission (hereinafter referred to as the Commission).
The Commission must, within 3 working days from the date of receipt of the information, enter them into the unified register of registered notifications published on the official website of the Eurasian Economic Union.
Foreign economic activity participants should keep in mind that the notification is valid only from the date of entering the information about its registration in the Unified Register of Notifications. In other words, if there is no information about the notification in the Unified Register, then the customs have the right to refuse not only the release, but also the import of goods into the territory of the Union.
The most problematic moment for foreign trade participants in this case is the fact that the deadline for entering information about registered notifications into the Unified Register is far from always being observed.
The total period for registration of a notification (refusal to register a notification) and entering information about notifications registered with the coordinating body in the unified register of notifications in accordance with the current legislation should not exceed 10 working days from the date of submission of documents to the FSB of Russia. But if you open the Unified Register of Notifications, then numerous violations of the terms of publication of notifications become apparent.
It is not entirely clear what caused these delays: whether the FSB is delaying the transfer of data, or the commission is delaying its publication. But the fact remains that the entry of information about the notification into the Unified Register can take from one to three weeks, not counting the registration period of the notification itself. In this regard, importers should take this circumstance into account when planning supplies in order to avoid possible downtime and additional costs.
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