Details of Legal Regulation for Importing French Alcohol into Russia

1. LEGAL REGULATION FOR DIRECT SUPPLY OF ALCOHOL PRODUCTS

Analysis of the Russian alcohol product market shows that the demand for strong alcohol among Russians is decreasing, while interest in sparkling and still wines is growing, which is in line with the global alcohol market trends^[1]. At the same time, according to public sources, French wines take up only about 5% of the Russian market, largely due to decrease in production in the exporting country, as well as increase in the duty on imported wine. According to the International Organization of Vine and Wine (OIV), the year-on-year production volume in France dropped by 23% in 2024 due to unfavorable weather conditions^[2].

The turnover of wine products, including imported, as well as their quality control is governed by the Customs Code of the Eurasian Economic Union^[3] (the “EAEU Customs Code”), Resolution No.130 of the Eurasian Economic Commission Council dated November 12, 2021^[4] (“EAEU Council Resolution No.130”), Law No.171-FZ on state regulation of production and turnover of ethyl alcohol and alcohol products^[5] (“Law 171-FZ”), Law No.289-FZ on customs regulations^[6] (“Law 289-FZ”) and Law No.468 on viticulture and wine making^[7] (“Law 468-FZ”).

The law establishes the following requirements for turnover of alcohol products in the Russian Federation: mandatory licensing of activity in production and turnover of alcohol products, need to declare alcohol products and obtain certificates of quality, placement of excise stamp on alcohol products and placement of mandatory markings, which will be examined in this overview.

 

2. REQUIREMENTS FOR IMPORTING ALCOHOL PRODUCTS INTO RUSSIA

2.1.   Licensing for activity in turnover of alcohol products:

Under Clause 2 Article 18 of Law 171-FZ, licensing applies to buying, storing and supply of alcoholic and alcohol-containing products.

Under the general rule, the Russian legal entity importing the products will obtain the license. The license is issued by Rosalkogolregulirovanie (“RAR”), provided the following requirements are complied with:

(i)      In order to engage in turnover of alcohol products containing over 15% of ethyl alcohol by volume, an organization must have at least Ten Million (10,000,000) rubles in paid up charter capital (Clause 2.1 Article 11 of Law 171-FZ);

(ii)     In order to engage in turnover of alcohol products, an organization must own or lease for a term of at least One (1) year storage facilities that comply with the appropriate requirements (Clause 2.3 Article 11 of Law 171-FZ).

Please note that these requirements to not apply to retail sale of alcohol products.

A license for turnover of alcohol products is issued for a term no longer than five (5) years (Clause 28 Article 19 of Law 171-FZ). Under Subclause 94 Clause 1 Article 333.33 of the Russian Tax Code, the state duty for such a license is RUB 800,000 (about USD 10,200).

 

2.2. Access points at the Russian border:

Ethyl alcohol and alcohol products may be imported to the customs territory of the Eurasian Economic Union (the “EAEU”^[8]) only through strictly determined checkpoints determined by the Russian Government^[9]. In addition, import of alcohol products is done through specialized customs excise posts^[10], requiring that the logistics of such supply be planned in advance.

 

2.3. Records of imported alcohol products in the EGAIS system

Under provisions of Law 171-FZ, record of all imported alcohol products must be made in the Unified Automated Information System – EGAIS in order to perform analysis of information and control over the turnover of alcohol products. The importer must connect to the EGAIS system and record all operations it performs with alcohol (receipt, storage, shipping).

Connecting to the EGAIS system is mandatory. A legal entity can be fined for violation in the amount of RUB 50,000 to 100,000 (about USD 640 to 1,300) (per Article 15.13 of the Russian Code of Administrative Offences).

 

2.4. Certification of alcohol products

Alcohol products sold at retail in Russia must contain information on certification of the alcohol products or declaration of their compliance (Article 11 of Law 171-FZ).

For purposes of certification, alcohol products must comply with the following requirements and norms:

1. Technical Regulations of the EAEU 047/2018 “On safety of alcohol products” ^[11];
2. Technical Regulations of the EAEU 021/2011 “On safety of food products”^[12].

The form for confirming compliance is a declaration of compliance (for winemaking products, distillates, etc.) or a certificate of compliance (for ethyl alcohol). In order to import to the EAEU customs territory, a document on assessment of compliance (declaration or certificate) issued under EAEU rules or information on it in the register needs to be provided (EAEU Board Resolution No.130^[13]). Please note that the document on assessment of compliance must be obtained prior to the customs declaration.

 

3. IMPORT DUTY AND TAXES

3.1. Import customs duty (ICD)

The ICD rates are determined through the Unified Customs Tariff of the EAEU (EAEU UCT) based on the Foreign Trade Goods code (TN VED) of the EAEU (Resolution No.80 of the Eurasian Economic Commission Council^[14]).

TN VED code	Goods	Base rate
2204	Natural grape wines (including fortified)	12.5%
2205	Vermouths and natural grape wines	10%
2206	Other fermented beverages (hard cider, hard pear cider, honey drink)	12.5%
2208	Distillates (Cognac, Armagnac)	EUR 1.5 per 1 liter

 

3.2. Additional import duty (AID)

Goods originating from “unfriendly states” (including France) are subject to increased AID rates based on Resolution No.2240 of the Russian Government^[15].

TN VED code	Goods	Country	Effective term	Base rate
2203 00	Malt beer	All unfriendly states	Until 31.12.2025 inclusive	EUR 1 for 1liter
2204 10	Sparkling wines	All unfriendly states	Until 31.12.2025 inclusive	25%, but no less than USD 2
2204 21	Other wines; grape wort whose fermentation was prevented or suspended by adding alcohol, in containers of 2 liters or less	All unfriendly states	Until 31.12.2025 inclusive	25%, but no less than USD 2
2204 22	Other wines; grape wort whose fermentation was prevented or suspended by adding alcohol, in containers over 2 liters, but no more than 10 liters	All unfriendly states	Until 31.12.2025 inclusive	25%, but no less than USD 2
2204 29	Other wines; grape wort whose fermentation was prevented or suspended by adding alcohol, other	All unfriendly states	Until 31.12.2025 inclusive	25%, but no less than USD 2
2205	Vermouths and natural grape wines with additives of vegetative or aromatic substances	All unfriendly states	Until 31.12.2025 inclusive	25%, but no less than USD 2
2206 00 310 0	Hard cider and hard pear cider	All unfriendly states	Until 31.12.2025 inclusive	22.5%
2206 00 390	Other sparkling beverages	All unfriendly states	Until 31.12.2025 inclusive	22.5%
2206 00 510 0, 2206 00 590, 2206 00 810 0, 2206 00 890	Still hard cider and hard pear cider, other still beverages (in any volume)	All unfriendly states	Until 31.12.2025 inclusive	22.5%
2208 20, 2208 30, 2208 40, 2208 50, 2208 60, 2208 70, 2208 90	Whiskey, rum and other alcoholic liqueurs Gin, vodka, liqueurs	All unfriendly states	Until 31.12.2025 inclusive	20%, but no less than EUR 3 for 1 liter

 

3.3. Excise

Pursuant to Article 181 of the Russian Tax Code^[16], alcoholic products with over 0.5% ethyl alcohol by volume are subject to excise tax. The excise tax rate for wines (except fortified (liqueur) wines), fruit wines, as well as fruit alcohol products from January 1 to December 31, 2025 inclusive is RUB 113 for 1 liter (Subclause 13 Clause 1 Article 193 of the Russian Tax Code).

Calculation: Excise = (Shipment volume in liters * Strength in %) * Rate of excise per liter of ethyl alcohol.

 

3.4. Value-added tax (VAT)

The rate of the value-added tax (VAT) for alcohol products is 20% (Article 164 of the Russian Tax Code). The tax base is calculated as follows: Customs Value of the goods + ICD + AID + Excise.

VAT calculation: VAT = (Customs Value + ICD + AID + Excise) * 20%.

 

4. REQUIREMENTS FOR MARKING ALCOHOL PRODUCTS

4.1. Federal special stamp (FSS)

Under the special rule, the FSS is mandatory for all alcohol products (except beer, hard cider, etc.) imported into Russia for sale (Article 12 of Law 171-FZ, Decree No.2348 of the Russian Government dated December 29, 2020^[17]). The stamp contains protective elements and a unique bar code tied to data in the EGAIS system, and the importer must acquire it from Goznak prior to importing the shipment. The federal special stamp costs RUB 2,050 for 1,000 stamps, not including VAT (about USD 30). The stamp is to be glued onto each consumer container (bottle, can) prior to crossing the border or at a temporary storage facility under customs control.

 

4.2. Digital marking (Chestny Znak)

Mandatory within the system for marking goods in the Russian Federation (Resolution No.43 of the Eurasian Economic Commission Council “On introducing marking of alcohol products by identification means” dated 23.04.2021). Each unit of the product must be marked with a Data Matric code that contains a unique crypto identifier. Information on the codes is recorded in the Chestny Znak system and correlates with the EGAIS system. The importer must be registered in the Chestny Znak system and acquire the marking codes.

 

4.3. Contents of the alcohol product label

The label on alcohol products must comply with requirements of Technical Regulations of the EAEU 047/2018 (name, manufacturer, importer, contents, strength, volume, date poured, expiration date, hazard warning, etc.) and Russian laws (Law 171-FZ, Consumer Protection Law^[18]). Information on the label must be in Russian and may also contain a foreign language version.

Manufacturers and entities engaged in retail sale of winemaking products must ensure the consumer has information on the type of the winemaking product and the manufacturer, on the type(s), place of origin and harvest year of the grapes used when making the winemaking product being sold, irrespective of the place it is produced (Article 26 of Law 468-FZ).

 

Regardless of the large number of special requirements for importers of alcohol products, in particular, winemaking goods (licensing, certification, marking of the goods), as well as the increased amount of import duty, French alcohol will continue to be of interest to buyers in a particular segment who understand the collection value of such product and have a refined taste. Also, as noted by the mass media, the increase in duties for wine imported from so-called “unfriendly states” has not restricted the import of alcohol product from France^[19], which shows that there is sustained cooperation in the import of French alcohol.

 

We hope this overview on the main requirements for importing French alcohol to the Russian Federation was useful for you. We will be glad to answer any questions that could come up and propose the best ways to resolve issues.

 

Additional information

Should any questions arise in connection with the above or if you need any additional materials, please contact the CLS office in St. Petersburg or Moscow.

This information letter keeps clients of CLS and other interested parties abreast of information that may, to some extent, affect their activity or cater to their interests. The opinions and commentaries expressed in this information letter shall not be deemed legal advice and do not cancel the need to obtain legal advice or legal opinion on separate issues.

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