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Change of legal address! Consequences in the Certificate

08.06.2020

Change of legal address! Consequences in the Certificate

Changing the address of a company is quite an ordinary procedure faced by Russian participants in foreign economic activity. In this case, a legitimate question arises about the consequences of this action: is it required to reissue the permits?

According to paragraph 93 of the Decision of the Council of the Eurasian Economic Commission of 18.04.2018 N 44 "On standard conformity assessment schemes" (hereinafter - Decision 44), it is allowed to replace the certificate of conformity of products and (or) annexes to it without performing any procedures provided for by the certification scheme, when changing the organizational and legal form or address of the legal entity of the applicant.

It should be noted that the practice of accredited persons is ambiguous due to different approaches to the interpretation of this provision:
  • you can reprint the form of any certificate;
  • reprinting the forms of certificates is permissible only in relation to certificates of compliance with technical regulations that entered into force after the adoption of Resolution 44, in other cases it requires the issuance of a new certificate of compliance;
  • Reprinting of certificate blanks is permissible only for certificates of conformity after the adoption of Decision 44.

 Obviously, against the background of organizational and legal changes in recent years, the conformity assessment procedure carries serious costs for the applicant. In this regard, a meeting held at the end of 2019 with the participation of representatives of the Ministry of Economic Development of Russia, the Ministry of Industry and Trade of Russia, Rosaccreditation and the Federal Customs Service of Russia deserves attention.
 
During the discussion of the application of the relevant provisions of the legislation, the participants in the discussion concluded that there was no need to replace the certificate of conformity in the event of a change in the location (address of the legal entity) of the applicant and recommended that the Federal Customs Service of Russia proceed from this position when exercising customs control.

Have a question? Call 8 499 647-75-64 or write info@notifikat.ru

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