Classification decisions for equipment imported in separate components

Short answer: a special classification decision is available for goods crossing the border as separate components in an unassembled or disassembled state, including an incomplete or unfinished state. Where the conditions in Article 117 of the EAEU Customs Code are met, components may be declared through several declarations using the code of the complete or finished product. Eligibility must be checked for the specific project; splitting a shipment into consignments does not create it automatically. EAEU Customs Code, Articles 21 and 117.

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When to consider this approach#

The question often arises when planning an import of a large installation, production line or other complex equipment. Commercially, the project may involve one object, while physically it arrives in several consignments: structures, operating assemblies, drives and control systems may be shipped separately.

The first question is what constitutes the finished product and how each supplied component relates to it. A project name such as “turnkey factory” does not explain this by itself. Several independent machines may operate at the same site, but their classification as one product requires separate justification under the EAEU Commodity Nomenclature for Foreign Economic Activity (TN VED).

Check whether the special arrangements apply before fixing the configuration and dispatch schedule. Article 21 provides for a list of goods for which the relevant decisions may be issued. EEC Board Decision No. 45 of 3 April 2018 approved that list; its current amendments must be taken into account. It is therefore incorrect to assume that all equipment qualifies. EAEU Customs Code, Article 21; Decision No. 45 in the ARLIS state legal information system.

How the decision relates to component declarations#

Article 117 describes a component as a constituent part of a finished or complete product identified as such in the relevant decision. Linking shipments to the component list is central to preparation: the actual dispatch must be traceable to the description in the documents. EAEU Customs Code, Article 117.

The Code sets several conditions that must be met together: a decision must have been issued; the declarant of the components must be the person to whom it was issued; all components must be declared to one customs authority; and imported components must be addressed to one consignee. National legislation may add requirements within the framework established by the Code. Check these conditions before selecting shipment arrangements. EAEU Customs Code, Article 117, paragraphs 3–5.

In practice, the technical description, contractual documents, parties to the shipment and customs arrangements need to be consistent. Transport planning should not run ahead of the assessment of how each consignment will be declared.

How this differs from an advance decision#

QuestionAdvance classification decisionDecision for goods imported in components
Main purposeClassify a specific product in advanceDetermine classification of unassembled or disassembled goods for the relevant arrangements
What is describedThe product designation and specific versionThe finished product and its constituent components
Why shipment arrangements matterThey establish the circumstances of the applicationThey are connected to conditions for special declaration arrangements
Legal basisArticles 21 and 23–27 of the EAEU Customs CodeArticles 21 and 117 of the EAEU Customs Code and national regulation

Article 21 of the EAEU Customs Code expressly distinguishes these areas. If the task is to determine a particular product's code before declaration, start with the advance decisions guide. For general classification principles, see our TN VED guide.

What to collect for an initial review#

The following list is a working tool for project preparation. It helps identify gaps before the formal application package is assembled.

MaterialQuestion it answers
Description of the finished productWhat will exist after assembly and what function will it perform?
Overall process diagramHow are the main assemblies linked, and what operations do they perform?
Component listWhich items form the product, in what quantities and under which identifiers?
Technical data sheets and drawingsHow are the characteristics of the product and its assemblies substantiated?
Contract specificationsDoes the contractual configuration match the technical description?
Preliminary consignment scheduleWhich components will be dispatched, and in what sequence?
List of independent itemsWhich spare parts, tools or other goods require separate analysis?

Reconcile the names used in these materials through a cross-reference table. For example, a manufacturer's internal assembly number should be identifiable in both the specification and consignment plan. If one unit has three different descriptions, link them through its article number or diagram position.

Working component register

An illustrative template, not a prescribed form.

UnitPart number/diagram referenceSpecificationPlanned shipmentActual shipmentDeclaration documentChange to clarify
Fictional unit AInternal reference A-01Illustrative item 1FirstNot yet dispatchedNot enteredDescription needs clarification

All names and references in this row are fictional. Completing the table does not automatically make the special procedure applicable.

Use one component register to keep the specification and shipment plan consistent. When preparing a decision for equipment imported in components, describe the finished product, its component units and the current shipment stage. If some units have already been dispatched, mention this in the initial enquiry.

Do not fill missing characteristics by analogy with a similar model. Record the question for the manufacturer and obtain an answer. In a large project, it is useful to designate one person responsible for the current component list and its changes.

Preparing the project#

  1. Define the product's boundaries. Separate the object itself from consumables, additional equipment and independent goods. Reserve uncertain items for individual analysis.
  2. Check legal eligibility. Compare the product against the current nomenclature, applicable list and special procedure conditions. The nomenclature is available on the EEC website.
  3. Reconcile the technical package. Ensure that the functional description, diagram and component list are consistent.
  4. Connect the documents to shipments. Identify the consignee, intended declarant, authority to which declarations will be submitted, consignment contents and project schedule.
  5. Prepare the application. Check the current application requirements, applicant authority and submission channel under the applicable Russian rules. Review separately which actions are required before declaring the first consignment.
  6. Set up execution controls. Once a decision is issued, compare every dispatch with its contents and assess project changes promptly.

For electronic interaction, see the Russian FCS personal account guide and consulting on its use. Delivery schedules and contractual preparation can be reviewed alongside Incoterms delivery terms.

What to monitor when the shipment changes#

After documents have been prepared, the supplier may substitute an assembly, add spare parts or postpone the final consignment. Refer such changes to the specialist responsible for the project's customs arrangements first. Check whether the description, component list and clearance conditions still match the actual project.

Completion of the shipment needs particular attention. If the circumstances specified in Article 117(9) of the EAEU Customs Code arise, declaration information must be amended to replace the complete product's code with the component codes. These circumstances include missing the established deadline for declaring the final component and termination or revocation of the decision before that deadline. Check the amendment procedure and deadline for the particular project circumstances. EAEU Customs Code, Article 117, paragraphs 8–9.

A useful working register follows this sequence: component position → manufacturer document → planned consignment → actual consignment → declaration document. Its primary purpose is to check completeness and changes, rather than simply maintain an archive.

Frequently asked questions#

Can every production line be cleared under one code?

There is no automatic entitlement based on the commercial name. The finished product's classification, applicable list and procedural conditions must be assessed. EAEU Customs Code, Articles 21 and 117.

Are spare parts covered by the decision too?

They cannot be included solely because they are supplied under the same contract as the equipment. First establish their purpose, the product configuration and the decision's scope. Independent items need separate analysis; Article 117 of the EAEU Customs Code links a component to a constituent part identified in the decision.

Can we dispatch a consignment first and prepare the documents later?

Do not plan on that basis without assessing the circumstances. Special declaration arrangements depend on a decision and compliance with the relevant conditions. If anything has already shipped or been declared, disclose this at the start: it affects the available sequence of actions.

Does the decision guarantee lower customs payments?

No. Article 117 provides for the applicable regulatory measures, tax rates, prohibitions and restrictions for the complete product under the established arrangements. Calculate the financial outcome for the particular project; a decision alone is not a basis for promising savings. EAEU Customs Code, Article 117, paragraph 7.

How Senateks can help#

Through our classification decision support service, we help collect information, check the consistency of technical documents and prepare application materials. Start by sending an object description, component list and consignment plan. The customs authority makes the classification decision; we agree our scope of support after reviewing the project.

Sources

  1. Treaty on the EAEU Customs Code — Articles 21 and 117
  2. EEC — EAEU Commodity Nomenclature and Common Customs Tariff
  3. EEC Board Decision No. 45 of 3 April 2018 — original act in ARLIS