Marketplaces · May 14, 2026
EAC mark and Chestny ZNAK: what must be on the packaging
How the EAC mark differs from labeling codes, and what is mandatory on the label.
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6 min
The labelling system expands according to one scenario: first an experiment, then mandatory registration of participants, then mandatory application of codes, followed by a ban on the circulation of unlabelled goods and the transfer of information on every sale. In 2026, different product groups are at different steps of this ladder.
What happens in 2026
Key dates of the year
FebMedical devicesNew categories, including means for correcting functional disorders
JunPolymer pipesStart of mandatory labelling
all year15 groupsNew stages for categories that are already labelled
DecItem-level trackingTransition to tracking every unit of goods
The exact dates and the lists of HS codes (TN VED) are published by Government decrees for each group separately.
Who is affected
The obligations are spread along the whole chain, and “we only sell” does not release you from participation in the system.
| Participant | What it does |
|---|---|
| Manufacturer | Orders codes, applies them, puts the goods into circulation |
| Importer | Receives codes before import, applies them before crossing the border or at a temporary storage warehouse |
| Wholesale link | Receives and transfers information through electronic document management |
| Retail and marketplace | Withdraws goods from circulation on sale, checks codes at acceptance |
A common importer error
Codes must be obtained and applied before the goods are put into circulation, not after the batch has arrived at the warehouse. Relabelling a batch that has already been brought in is a separate procedure with its own risks.
Item-level tracking: the main change of the year
Until now, many groups allowed tracking by aggregated packages: a box, a pallet, a batch. Item-level tracking means that each unit of goods moves along the chain with its own code, and each transfer is recorded by an electronic document.
How it was
- Batch tracking, reconciliation by quantity
- Paper waybills are acceptable
- Discrepancies are found during stocktaking
How it will be
- Each unit is traced separately
- Electronic document management is mandatory
- A discrepancy blocks acceptance immediately
A detailed review of how to prepare for this transition is in a separate article.
How to join if the group is new
- Obtain an enhanced qualified electronic signature
- Register in the labelling system as a market participant
- Connect electronic document management with counterparties
- Describe the product in the catalogue and obtain product codes
- Order identification codes and organise their application
- Check the equipment: printers, scanners, cash register software
How labelling is related to certification
These are two independent requirements that are often confused. A conformity document confirms that the product is safe and conforms to the technical regulation. A labelling code confirms that a specific unit has been legally put into circulation. A product may require both at the same time — and the absence of either one stops sales.
When a product is described in the labelling catalogue, the information from the permit document is stated, so the order of actions is usually this: first a declaration or certificate is issued, then the product is described and codes are ordered. How to understand which document is needed is covered in the basic article.
What to check before the end of the year
- Whether your HS codes (TN VED) are on the lists of the new groups
- Whether electronic document management is set up with all counterparties
- Whether the product cards in the catalogue are ready and whether the information on documents in them is correct
- Whether the capacity of the equipment will be enough for the transition to item-level tracking
- Who in the company is responsible for ordering codes and withdrawal from circulation
The year by dates
What 2026 looks like for a market participant
February 1Medical devices
Mandatory labelling of new categories starts, including means for correcting functional disorders of the body.
June 1Polymer pipes
A new product group joins: registration of participants, description of goods, application of codes.
During the yearTransition stages
For fifteen groups that are already labelled, intermediate stages are completed — from the permissive regime to the ban on circulation without codes.
December 1Item-level tracking
Transition to tracking every unit of goods. By this moment electronic document management must work with all counterparties.
The exact lists of codes for each group are approved by separate decrees.
What is technically needed at the warehouse
Labelling is not only codes on the packaging but also a minimum of infrastructure. It is impossible to work without it, and buying it in a rush is more expensive.
| What is needed | Why |
|---|---|
| Enhanced qualified electronic signature | Registration in the system, signing of documents and operations |
| Personal account in the labelling system | Ordering codes, reports on application, withdrawal from circulation |
| Electronic document management | Acceptance and transfer of goods go through universal transfer documents |
| Two-dimensional code scanner | An ordinary linear barcode scanner does not read labelling codes |
| Label printer with sufficient resolution | A poorly printed code cannot be read and becomes a defect |
| Inventory system with labelling support | Otherwise codes are tracked manually and the process falls apart at the first hundred items |
About printing
The most frequent technical problem is an unreadable code. The causes are mundane: low print resolution, saving on the ribbon, printing on glossy material, damage during transportation. A code that cannot be scanned is treated as absent, and relabelling requires a separate procedure and write-off of the old codes.
How the life cycle of a code works
A code goes through several states, and each transition must be recorded in the system. A missed step leaves the goods “hanging” in circulation.
- Issue. Codes are ordered in the system for specific products.
- Application. The code is printed and applied to the packaging, and a report on application is submitted.
- Putting into circulation. The goods become legal for sale.
- Circulation. Transfer between participants is recorded by electronic documents.
- Withdrawal from circulation. Sale through the cash register, sale to a legal entity, write-off in case of damage or loss, use for own needs.
Withdrawal from circulation is the place where records and reality diverge most often. The goods have physically been sold or spoiled, but in the system they are still in circulation: the balances do not match, and during an inspection this looks like unaccounted products.
What to do with unlabelled stock
When a new product group is introduced, there is always a stock purchased before the start. The order of actions is the same for most groups.
- Carry out a stocktaking before the date of the ban on the circulation of unlabelled products
- Describe the stock and order codes under a simplified scheme, if one is provided for the group
- Label it and put it into circulation within the transition period given
- What you did not manage to label — do not sell: selling unlabelled goods after the ban date is a violation
- Take into account that the transition periods for stock differ from the periods for new deliveries
An error that is expensive: buying a large batch just before the start of mandatory labelling in the expectation of “I will sell it under the old rules”. If the group moves to item-level tracking, there may simply not be enough time to sell under the old rules.
Import of labelled goods
For import the procedure is stricter than for domestic production: codes are applied before the border is crossed. This means that labelling is done either by the foreign supplier using your codes, or by you at a customs warehouse.
- Codes are ordered in advance and passed to the manufacturer as a file
- Application on the supplier’s side requires control of print quality — redoing it after import is expensive
- The option of application at a temporary storage warehouse requires separate logistics and time
- Information on the import is submitted to the system during customs clearance
Liability
Violations are divided into three groups, and their consequences differ.
| Violation | What follows |
|---|---|
| Sale of unlabelled goods | Administrative liability with confiscation of the products |
| Application of codes in breach of the procedure | A fine; the goods are considered unlabelled |
| Failure to submit information to the system or submitting false information | A separate offence, fined regardless of whether codes are present |
| Large turnover of unlabelled products | May be classified as something other than an administrative offence |
It is worth remembering separately: labelling and conformity confirmation are different obligations. Having codes does not replace a declaration, and a declaration does not replace codes. Both are checked, independently of each other.
Check your product
Describe your product in plain words — the system will show the expected HS code (TN VED), the applicable regulations and the set of documents. Start the check.
