We are displaying 8 digit HS codes on our commercial invoices & issuing original copies to consignees in Russia.
We are have been advised today that the Russian authorities will not accept 8 digits and the shipper (us) must provide 10 digits, which our ERP system is not calibrated to do.
Who is correct: is it mandatory to provide 10 digits for export, as we understood the importer of record provided the last 2 digits on importation?
It sounds like the codes that you are declaring are being used by your client on their import declarations. UK export codes will not be acceptable as Russian import codes.
If you would like assistance with the correct Russian import codes please contact Cotecna direct at email@example.com and we will be happy to assist
According to Harmonized System products code consists of 6 digits, EU System – 8 digits and Russian System – 10 digits. Unfortunately, Russian customs can make changes to their regulations with little or no notice and if they are commanding the 10-digit code, then this must be adhered to (even if the last two digits are only “00”).
If you cannot change your calibrated systems to accommodate the 10-digits, you could possibly include the full number within the description box of your invoice and customs documents. But that would definitely be a question for your forwarder.
All the best
The relevant law is Russian law. So, the SAD 41 must comply with the Russian requirement. Albion have already suggested a good way around the ERP problem from a legal point of view, although the Russian EDI system might still throw out a mere 8 digits requiring someone in your logistics chain to do a manual override.