What manufacturers and exporters need to know in October 2026!
In October 2026, the reliability of EAC conformity documentation once again became a central focus. The Eurasian Economic Commission further detailed its plans to address unreliable certificates and test reports. At the same time, amendments for perfumery and cosmetic products entered into force. Extended transitional provisions were adopted for crude oil.
For manufacturers and exporters, understanding the legal status is crucial: product requirements already in force must be distinguished from adopted transitional arrangements and initiatives still undergoing coordination. This article continues the monthly overview and explains selected developments and their practical implications.
Measures against unreliable EAC certificates
On 22 October 2026, the Eurasian Economic Commission presented a prepared package of measures to address violations in conformity assessment. It is intended to strengthen product safety, make the use of unreliable documentation more difficult and combat violations by certification bodies and testing laboratories.
Following publication, the document was submitted to the governments of the five EAEU member states for coordination. The proposed approaches are to be presented to the Eurasian Intergovernmental Council in December.
Thus, the full package of measures had not yet entered into force as binding new rules in October. The publication describes the status of preparations and the further coordination planned.
Faster cooperation between authorities
As early as 12 October, the Commission outlined two planned areas of action. In the short term, authorities are to be able to cooperate more quickly within their existing powers, exchange documents more easily and handle complaints more efficiently.
Long‑term plans include more systematic cooperation between accreditation and market surveillance authorities, legal rules for recording test reports and improvements to national accountability arrangements. This publication also concerns proposals that must undergo further coordination and approval steps.
Our practical recommendation is therefore to keep all supporting documentation for an EAC procedure available. In the event of queries, it should be possible to establish which product was tested, who performed the testing and on what basis the conformity document was issued.
Test reports and digital information exchange
In its publication of 26 October, the Commission reported on consultations among national accreditation authorities. One focus was a planned procedure for information exchange intended, among other things, to make it possible to confirm whether a test report was actually issued.
The preparation of a new version of the common information process for the unified register of conformity assessment bodies was also discussed. According to the announcement, its launch is provisionally scheduled for the end of the first quarter of 2027. This plan concerns the register of bodies and must not be equated with an already completed transition of all certificate registers.
What businesses should prepare
We recommend maintaining documentation clearly assigned to each ongoing approval project:
- Complete test reports with number, date and issuing laboratory
- Description and identification of the products or samples tested
- Assignment of test reports to models and product families
- Details of the certification body and the relevant scope of accreditation
- Evidence of sample importation, where required for the procedure
- Documentation of subsequent changes to products or production sites
This compilation is a recommendation for preparing for queries. It does not constitute a new general documentation obligation introduced by the October consultations.
Amendments for perfumery and cosmetics
On 28 October 2026, amendments to the Technical Regulation on the Safety of Perfumery and Cosmetic Products entered into force. They are based on EEC Council Decision No. 74 of 12 September 2025.
The lists of prohibited and restricted substances, as well as permitted colourants, preservatives and UV filters, are being updated.
A separate amendment will follow on 1 January 2027: according to the EEC announcement, the statement “Contains formaldehyde” will be required in future if the maximum theoretically releasable formaldehyde concentration exceeds 0.001 percent. The announcement states that the previous threshold was 0.05 percent. This labelling threshold must not be confused with a general permissible formaldehyde content.
For affected product ranges, we recommend reviewing formulations and labelling together. Up‑to‑date composition data should be available for this purpose, and changes to raw materials should be documented. Packaging already printed, planned production batches and existing approval documentation must be assessed against the applicable transitional provisions.
Extended transitional provisions for crude oil
On 28 October 2026, the Eurasian Economic Commission reported on the extension of transitional provisions under the Technical Regulation on the safety of crude oil prepared for transport or use.
The transitional provisions concerned are intended to apply until 1 January 2030. This is due to difficulties in complying with the specified hydrogen sulphide levels, partly because of insufficient availability of suitable, safe binding agents on the Union market.
According to the announcement, the amending decision enters into force 30 calendar days after its official publication. The announcement of 28 October therefore does not mean that the extension was already applicable on that date.
The provision is product‑specific. It cannot be applied to all petroleum products or to machinery, pressure equipment or installations for the oil industry.
Implications for manufacturers of machinery and installations
For machinery manufacturers and suppliers of installations, the initiatives concerning the reliability of test reports and cooperation between authorities are particularly relevant. We therefore recommend checking existing approval documentation for completeness and clear identification of the products covered before applying for extensions or submitting new applications.
A comparison of the following is particularly helpful:
- Product designation and actual function
- Models listed in the conformity document and in the current product range
- Manufacturer details and production sites
- Tested configurations and subsequent technical modifications
- Test reports and the evidence of conformity based on them
The October announcements described do not establish a blanket obligation to replace all existing machinery approvals. Whether action is required must be assessed on the basis of the specific product, the document and the applicable regulations.
What companies should specifically check now
We recommend the following steps when planning for the coming months:
- Assign relevant changes to product groups
- Record entry‑into‑force dates and transitional provisions separately
- Compile all test reports and technical documentation
- Check register status and document details before planned deliveries
- Assess changes to formulations, models or production sites
- For cosmetics, take account of the additional labelling deadline in early 2027
- Define responsibilities among the manufacturer, applicant and bodies involved
Such an overview makes it easier to decide which products require immediate review and for which products further legal acts must first be awaited.
No. The publication of 22 October describes a prepared package that was submitted to the Member States for coordination. The approaches are to be presented at intergovernmental level in December. Individual regulations currently in force and subsequent implementing acts must be considered separately.
The October announcements reviewed describe the expansion of digital procedures and related initiatives. They do not establish that a uniform new registration obligation for all test reports has already been introduced in all EAEU Member States.
The Commission provisionally indicates the end of the first quarter of 2027 for the new version of the common information process for the register of conformity assessment bodies. This reflects the current planning status, not a confirmed launch date for all EAC registers.
The priority is to check formulations against the updated substance lists. In addition, manufacturers should check whether the formaldehyde labelling announced for January 2027 onwards is relevant.
No general renewal obligation can be inferred from this. The determining factors are the product group concerned, the specific legal act, any transitional provisions and the status of the respective document.
No, such an extension of scope cannot be inferred from the announcement. The extension concerns certain transitional provisions for the petroleum covered by the regulation. Equipment and installations must be assessed separately.
