Electronic conformity documents: how the FGIS register works

Just a few years ago, checking a document came down to examining the form: the hologram, the seal, the signature. Today none of this matters — what matters is the record in the state information system.

What the record contains

How to read the statuses

What a counterparty sees

The register is open: any buyer, marketplace or customs authority can check a document by its number. This changes the practice of work — it is impossible to hide a problem status, and a discrepancy between the product card and the record in the register is found within a minute.

Order of checking before a deal

• Find the record by the document number, not by the company name
• Compare the name of the product with what is stated in the contract and on the label
• Check whether your HS code (TN VED) is in the list in the record
• Make sure that the applicant is your counterparty or that it has the right of use
• Look at the basis: whether test reports are listed and who issued them
• Check the accreditation of the laboratory that issued the test report
• Save an extract with the date of the check

Frequent discrepancies

What to do if the document was suspended after sales had already started is covered in a separate review. How to choose a laboratory so as not to get into this situation is covered here.

What is needed to register a declaration yourself

Registering a declaration is an action of the applicant, and an intermediary is not mandatory for it. The set of requirements is small, but every item is blocking: without any one of them the procedure will not start.

• An enhanced qualified electronic signature for a person entitled to act without a power of attorney, or a power of attorney for the signatory
• Registration of the organisation in the identification system and access to the personal account
• Test reports of an accredited laboratory with information that will match the declaration
• Information on the product: name, manufacturer, HS codes (TN VED), designation of the normative document
• Understanding of the scheme: serial production or a batch, and under which scheme exactly the declaration is accepted

The most frequent delay is the signature. Issuing it takes time, and without it you can neither submit nor sign. If the declaration is needed by the delivery date, the signature is arranged first, not last.

What the buyer’s check of a document looks like

It is useful to look at your document through the eyes of the one who will check it: a retail chain buyer, a platform manager, a customs representative. They all look at the same things.

1. They find the record by number — if there is none, the conversation goes no further.
2. They compare the status: valid, suspended, terminated, archived.
3. They compare the name of the product with what is on the packaging and in the card.
4. They look at the manufacturer: whether it matches the one stated on the label.
5. They check whether the document was valid on the date of delivery, not only today.
6. For the batch scheme — they compare the batch information.
7. They check the laboratory from the test report: whether the accreditation is valid and whether the scope is the right one.

Each step takes seconds, so counting on “they will not notice” does not pay off. How to read a laboratory card is covered in a separate article.

What to do about an error in a registered declaration

A typo in the name, a wrong HS code (TN VED), an incomplete list of models — these are usually found after registration, when the document has already gone to counterparties.

• An error in the product information. As a rule, termination and registration of a new declaration are required: the content of a document cannot be changed retroactively.
• The applicant’s details have changed. This is handled by the procedure for making amendments, without full reissuing.
• The list of models is being extended. A new declaration or a supplement — it depends on whether the new items are covered by the existing evidence base.
• The product has changed. The previous declaration no longer describes it — a new one is needed, regardless of the remaining term.

A practical rule: the earlier an error is found, the cheaper it is. For a declaration under which half a year of deliveries has already been shipped, reissuing leaves open the question of what covered those shipments.

Paper copy and electronic record

A question that still causes disputes at acceptance: is a printout with a seal needed. Legal force comes from the record in the register, not from paper. A printout is a convenient form of presenting the information, nothing more.

Practical consequences follow: a scan without a record in the register confirms nothing; a seal on a printout adds nothing; if the paper and the register differ, the record in the register is correct. If a counterparty insists on an “original with a blue seal”, the simplest thing is to send a link to the register card — it holds the same information at its primary source.