Specifics of registration of notifications in the EAEU countries

Cryptographic means
Principal legal acts
	2.19. Encryption (cryptographic) means; Regulation on Notification;
IFCG services
	Obtaining permits for importation of cryptographic means: FSS Notification; Other related services: Importation of wireless (radio) products; EAC Certificates and Declarations; Customs consulting;

In the course of import to the EAEU (or export from the EAEU) of products with encryption, importers (exporters) should provide a special permit to the customs. In most cases this permit will be a Notification.

Notification is a document issued by the product manufacturer or its official representative, for example, its importer or distributor in the EAEU. The document is submitted for registration to an approving authority of the EAEU member country.

In spite of common requirements to execution of notifications for the whole Union in general, each EAEU country has its own peculiarities in registration of documents.

Registration of notifications in Russia

The state body authorized to register notifications in Russia is the Federal Security Service (FSS or FSB), or more specifically, its special division — the Center for Licensing, Certification and Protection of State Secrets [1].

In Russia documents should be submitted for registration only in hard copies. Originals of all documents are required, including the manufacturer’s Power of Attorney. Upon the registration, the applicant receives a copy of the registered notification with a number assigned to it. Information about registered notifications is sent to the Eurasian Economic Commission for publication in the Common Register of Notifications.

In Russia notification can only be registered for products which by their name and HS code fall within the Chapter 2.19 (the list of Encryption (cryptographic) means). Besides, requirements to the compiled notification are very stringent, FSB will refuse to register it even in case of a slight mistake.

Registration of notifications in Kazakhstan

The agency authorized to register notifications in Kazakhstan is the National Security Committee (KNB) [2].

In Kazakhstan documents are submitted for registration in the electronic form online on the government website. The application should be signed with a secure digital signature. After the registration the applicant receives a notice to the personal account on the site. Electronic execution of the Notification offers some benefits, as there is no need to submit original documents (e.g., the manufacturer’s Power of Attorney) – an electronic scanned copy will suffice.

Unlike FSB in Russia, KNB of Kazakhstan may approve a notification for those products that do not fall within the Chapter 2.19, e.g., for video cameras, headsets, monitors, etc., although issue of the notification for such goods is not required according to Chapter 2.19.

Registration of Notifications in other EAEU countries

The agency authorized to register Notifications in Armenia is the National Security Service [3]; in Belarus — the State Security Committee [4]; in Kyrgyzstan — the State Committee for National Security [5].

In Armenia documents for registration may be submitted either on paper or in electronic form (signed with a digital signature). In Belarus the application and documents should be submitted to the KGB in hard copies.

As of May 2020, Kyrgyzstan has not approved a single notification, the law of this country does not stipulate any procedure for submission of documents for registration of notifications.

Common Register of Notifications

Upon registration of a notification by an authorized authority information about it is sent to the Eurasian Economic Commission (EEC), which records information about the Notification to the Common Register of Notifications [6] (hereinafter — the Register), published on the official website of the EAEU.

The Register contains information about all active and currently cancelled notifications registered in the EAEU.

The Register provides the following information about a notification:

number,
identifier^[1],
product manufacturer,
product name,
date of publication of the notification,
period of validity,
status,
date of cancellation,
date of registration of the notification.

Each registered notification is assigned a unique registration number (e.g. RU0000012345), with its first letters designating the country that issued the notification. Letters RU, KZ, BY, AM in the notification number mean Russia, Kazakhstan, Belarus and Armenia, respectively.

Where are notifications registered most often?

As of May 2020, the Register contains information about more than 37,000 of notifications.

Most notifications were issued in Russia — over 34,000. Over 2,000 notifications were registered in the KNB of Kazakhstan. Belarus accounts for a little over 400 registered notifications.

Armenia registered only a few notifications.

Kyrgyzstan still has not issued even a single notification.

Customs Procedures

Information from the Register about an issued notification may be used to import (export) an encryption product by any legal entity or individual. Presenting an original document on paper is not required, the notification number from the Register will be enough for customs authorities.

Notification registered in any of the five countries of the EAEU (Armenia, Belarus, Kazakhstan, Kyrgyzstan, Russia) and recorded to the Register is applicable in the entire territory of the EAEU.

Notes

↑ Notification identifier is a sequence of 1's and 0's twelve (sometimes eleven) digits long. Digit in each position means whether the product contains cryptographic means from the respective category