On May 7, 2015 the Russian Federal Service for Surveillance on Consumer Rights Protection and Human Wellbeing (Rospotrebnadzor) issued Letter No. 01/4955-15-39 imposing a ban on importation to Russia of certain hygiene products manufactured by “Procter & Gamble Ukraine”, as, allegedly, they do not comply with certain Russian and EEU sanitary and epidemiologic standards. The ban came into force starting from May 9, 2015. It has no grandfathering exception for deals in progress.
Since Russia and Belarus have a unified customs territory (i.e., within the Eurasian Economic Union (EEU) of Russia, Belarus, Kazakhstan and Armenia) without internal customs borders and customs control, further to Russia’s request and with effect as of the same date Belarus adopted a set of internal administrative measures to prevent possible re-exportation of the banned products form Belarus to Russia. In particular, on May 8, 2015 the Ministry of Health of Belarus issued Letter No 24 prohibiting exportation and re-exportation of the products from Belarus to Russia (came into force starting from May 9, 2015). Notably, the importation and distribution of the target products in Belarus is not prohibited, but all their supplies are now subject to special monitoring and control. Additionally, the shipping documents for the products should have a special stamp confirming that their exportation from Belarus to Russia is prohibited.
Notably, this is not the first time when Ukrainian-origin products are banned in Russia. For example, Rospotrebnadzor earlier this year imposed a similar import ban on household chemicals manufactured by Ukrainian subdivisions of “SC Johnson”, on salt manufactured by “Artemsalt”, as well as on certain Ukrainian manufacturers of milk, diary and cheese products, and all juice products originating from Ukraine. The risk that the Russian import ban will be further extended to apply to other categories of products originating from Ukraine is very high. Therefore, the companies that have manufacturing sites in Ukraine are recommended to take this risk into account.
