Guide

EAC for Cosmetics: EAEU Declaration and Registration

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Contents · 8 sections
  1. Step 1: Check export controls, payment and logistics first
  2. Step 2: Decide between declaration and state registration
  3. Step 3: Appoint an applicant registered in the EAEU
  4. Step 4: Prepare the technical file and tests
  5. Step 5: Put the required information on the label in Russian
  6. Step 6: Apply the EAC mark
  7. Step 7: Watch for amendments
  8. Related reading and pages

In short: “EAC certification” for cosmetics means passing conformity assessment under the Customs Union technical regulation TR CU 009/2011 before the goods are placed on the market in the Eurasian Economic Union (EAEU).

Most cosmetics need a declaration of conformity; 14 listed categories, such as tanning, skin-whitening and children’s products, need state registration. In both cases the applicant must be a company registered in an EAEU member state, the label must carry the required information in Russian, and the product must bear the EAC mark.

The EAEU has five member states: Armenia, Belarus, Kazakhstan, the Kyrgyz Republic and Russia (Eurasian Economic Commission1). The regulation was adopted by Customs Union Commission Decision No. 799 of 23 September 2011 and has applied since 1 July 2012 (EEC page for TR CU 009/20112).

Article and appendix numbers below follow the consolidated Russian text in the Kazakhstan legal database (TR CU 009/2011, consolidated).

Step 1: Check export controls, payment and logistics first

Before any paperwork, confirm that the shipment can legally leave Korea and be paid for. Korea’s trade ministry restricts exports of listed items to Russia and Belarus through “situational permission” (상황허가).

Its February 2024 notice alone added 682 items, bringing the list to 1,159, and said added items are in principle banned from export (MOTIE press release, 20 Feb 20243).

The list has changed more than once, so check your HS codes against the current notice with the Korea Strategic Trade Institute (전략물자관리원) and confirm with your bank and forwarder that payment and transport routes are open.

This step applies to Russia and Belarus; for Kazakhstan, Armenia or Kyrgyzstan, you still need to know where the goods will end up.

Step 2: Decide between declaration and state registration

Article 6 of TR CU 009/2011 sets two forms of conformity assessment. Products listed in Appendix 12 need state registration; everything else goes through a declaration of conformity. Appendix 12 lists 14 categories:

  1. Artificial tanning products
  2. Skin whitening (lightening) products
  3. Cosmetics for tattooing (permanent make-up)
  4. Intimate cosmetics
  5. Products for individual skin protection against harmful occupational factors
  6. Children’s cosmetics
  7. Products for chemical hair colouring, lightening and highlighting, including brows and lashes
  8. Products for chemical perming and straightening, including brows and lashes
  9. Products made using nanomaterials
  10. Depilation products
  11. Peels
  12. Fluoride oral care with more than 0.15% fluoride (0.05% for liquid products)
  13. Tooth whitening products with 0.1–6.0% hydrogen peroxide (as an ingredient or released)
  14. Family cosmetics intended also for children under 14

Note that sunscreens are not a separate category on the list, so an ordinary sunscreen for adults normally follows the declaration route. A sunscreen still needs state registration if it falls under another item, such as children’s cosmetics (6), products made using nanomaterials (9, which can include sunscreens with nano zinc oxide or titanium dioxide) or family cosmetics also intended for children under 14 (14). A Korean toner, serum or sheet mask without a whitening or children’s positioning would normally follow the declaration route.

Step 3: Appoint an applicant registered in the EAEU

A Korean manufacturer cannot apply on its own. Under Article 6, the applicant must be a legal entity or individual entrepreneur registered in a member state:

  • For state registration: the manufacturer, the importer (seller) or a person authorised by the manufacturer. For imported goods, registration must happen before the goods are brought into the EAEU.
  • For a declaration: under schemes 3d and 6d, the manufacturer or its authorised person; under scheme 4d, which covers a single batch, the importer (seller) can also apply. Scheme 4d needs the supply contract and shipping documents that identify the batch and its size.

In practice, the brand or exporter signs an authorisation with an EAEU company that will hold the declaration or certificate.

Step 4: Prepare the technical file and tests

The document sets for both routes overlap. From Article 6, expect to provide:

  • The manufacturer’s ingredient list with the function of each ingredient, and the mass fraction of ingredients restricted in Appendices 2–5.
  • Organoleptic and physico-chemical specifications.
  • Test reports from an accredited laboratory against Article 5 (paragraphs 3–6). For state registration, the reports must be no more than one year old when the application is registered.
  • A label mock-up showing compliance with Article 5, paragraph 9.
  • Evidence that production meets the regulation’s manufacturing requirements: a manufacturer’s notice, a GMP declaration, a quality-management certificate, or a GMP certificate.
  • For state registration, documents that support claims on the pack (for example SPF or anti-wrinkle), which must follow the general criteria in Appendix 13.

If you already keep a product information file for the EU or Taiwan, much of this can be reused; see our guide to the product information file (PIF).

Step 5: Put the required information on the label in Russian

Article 5, paragraph 9.5 requires the label information to be given in Russian, and also in the state language of the member state where the goods are sold if that state’s law requires it. Paragraph 9.2 lists the content, including:

  • Product name, and its purpose if the name does not make it clear. The name must not be the same as, or confusingly similar to, a registered medicine or medical device.
  • Manufacturer’s name and address including country, and the country of origin if production is elsewhere.
  • The organisation that accepts consumer complaints in the member state, if the manufacturer does not.
  • Nominal quantity; colour or shade for decorative products.
  • Shelf life in one of the formats the regulation allows, storage conditions if non-standard, precautions and warnings.
  • Batch number or code, directions where needed, and the ingredient list.

Children’s and family cosmetics must say so and state the age they are intended for. If the ingredients and precautions are on a leaflet or tag, the pack must carry the “hand on open book” symbol from Appendix 11.

Step 6: Apply the EAC mark

Article 7 requires products that have passed conformity assessment to carry the single mark of circulation (the EAC mark) before they are placed on the market. It goes on each unit (pack, tag or label) and/or on the shipping documents, applied so that it stays clear for the product’s whole shelf life.

Step 7: Watch for amendments

The regulation keeps changing. The EEC page2 lists amendments by Council Decisions No. 91 (2015), No. 32 (2019) and No. 64 (2022), and two more recent ones, No. 114 of 29 November 2024 and No. 74 of 12 September 2025. No. 114 has applied since 24 December 20254 and No. 74 applies from 28 October 2026; declarations and registration certificates issued before No. 74 took effect stay valid until they expire, except registration certificates issued without an expiry date, which follow earlier transition rules5. Check the version in force on the day you file, and ask your EAEU applicant to confirm the transition rules for documents already issued.

Digital marking is a separate track. Since 28 February 2026, EEC Council Decision No. 124 has let each member state set its own start date and procedure for marking certain cosmetics, personal hygiene and household chemical products6. For Russia, see Russia Chestny Znak marking.

The EAEU route has a lot in common with other markets that require a local registrant. Compare India’s CDSCO import registration, and see the overall Korean cosmetics export process.

SEONGWOO GLOBAL is a Korean cosmetics wholesale exporter with companies in Seoul and Hong Kong. Tell us the destination country and product list, and we can discuss what documents are needed on the supply side.

Brands we supply · FAQ · Contact us

See also: Korean cosmetics wholesale for Kazakhstan · Russia Chestny Znak marking · Kaspi, Wildberries and Ozon documents

Notes

  1. Eurasian Economic Commission, Eurasian Economic Commission, verified 2026-10-25. ↩

  2. Eurasian Economic Commission, О безопасности парфюмерно-косметической продукции (ТР ТС 009/2011), verified 2026-10-25. ↩ ↩2

  3. MOTIE, 러시아‧벨라루스 수출 통제 품목 확대, verified 2026-10-25. ↩

  4. Eurasian Economic Commission, 24 декабря вступят в силу изменения в техрегламент на парфюмерно-косметическую продукцию, verified 2026-10-25. ↩

  5. Eurasian Economic Commission, Установлен порядок введения в действие изменений техрегламента на парфюмерно-косметическую продукцию, verified 2026-10-25. ↩

  6. Eurasian Economic Union legal portal, Решение Совета ЕЭК № 124 от 05.12.2025, verified 2026-10-25. ↩

Written by SEONGWOO GLOBAL

Published · Updated

Corrections

· Sunscreens: the page said ordinary sunscreens are not on the state-registration list; it now says sunscreens are not a separate category there but need state registration if they fall under item 6, 9 or 14.

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