A biscuit manufacturer asked us recently: “Our product isn’t in scope — only chocolate was added.” In fact biscuits, wafers and Turkish delight had been in scope since 1 March 2026. That misreading ended with a shipment sitting at Russian customs. Russia’s mandatory labelling timetable rolled out across the food sector in three separate waves — and most companies only heard about the wave that concerned their own product.
As of today all three waves are in force. The next issue is not wider scope but deeper traceability: in 2027 and 2028 the system moves from “is there a code?” to “where is the paperwork for this code?”
Scope is already in force: three stages, three dates
According to the timetable reported in publicly available sources, confectionery and baked goods entered scope in three stages:
- 1 March 2026 — biscuits, wafers, marmalade, zefir, pastila, Turkish delight and similar oriental sweets, chocolate and nut spreads (including cocoa-based creams).
- 1 May 2026 — baked goods: cakes, pastries, rolls, croissants and sweetened bakery items (sweet buns and similar products).
- 1 July 2026 — chocolate products, dragées, caramel and chewing gum.
Registration in the system opened earlier, in autumn 2025. So if you are shipping an in-scope product to Russia today, your company registration should already be complete. Settle the scope question from the customs code, not the product name — “our product doesn’t really count as confectionery” is one of the most expensive assumptions in practice.
The detail most often missed: packaging and shelf life
There is a scoping condition in the baked goods stage that deserves attention. Under the regulation as reported, the obligation in this group arises where the product is in consumer packaging and has a shelf life longer than 30 days.
In practice: an unpackaged item baked and sold the same day is not treated like a packaged cake with months of shelf life. For an exporter this is rarely good news — the products that travel are precisely the packaged, long-shelf-life ones. Most baked goods shipped from Türkiye to Russia meet that condition directly and fall in scope.
If you are unsure which side your product falls on, get the packaging type and shelf life confirmed in writing. Those two facts decide the entire scope discussion.
What comes next: traceability deepens in 2027 and 2028
Labelling itself is settled. What changes over the next two years is how closely the code is tracked through documentation:
- 1 July 2027 — batch-level accounting (партионный учёт). Electronic document flow becomes mandatory on dispatch and goods receipt, with GTIN, quantity and batch number shown in the document. Obligations covering sets and group packaging are reported to begin on the same date.
- 1 December 2028 — per-unit accounting (поэкземплярный учёт). Documents will carry the individual labelling code of every single product unit.
The two dates are connected: batch-level accounting is positioned as the preparatory step towards per-unit accounting.
What batch-level accounting (2027) actually changes
For many companies the process today runs like this: the code is generated, printed on the packaging, and the goods ship. After 2027 one more link joins that chain — the batch a code belongs to must be visible in the document.
That means the document flow between you and your Russian buyer has to work electronically and consistently. In Russia this runs through EDO (электронный документооборот), using an electronic transfer document known as the UPD. If you have not set up EDO at all, we covered the subject in full in our EDO guide.
The most common blockage we see in the field is administrative rather than technical: the batch number produced by the exporter does not match the batch data the Russian buyer enters. When documents fail to reconcile, goods wait at receipt.
Why per-unit accounting (2028) needs planning now
2028 looks distant. But per-unit accounting is markedly heavier work on the production line and in the ERP than batch-level accounting.
Recording every single unit’s code, in a high-volume and low-unit-value category — which confectionery is exactly — directly affects line speed and data volume. Code-reading stations, serial-to-batch reconciliation and the recording architecture on the software side are not things you order and install in a week.
Our experience points one way: companies that compress these transitions into the final three months pay twice — once for rushed equipment, once for delayed shipments.
What makes code printing on food packaging different
- Packaging variety: Confectionery and baked goods are mostly sold in small, flexible or foil packaging. Whether to print directly or apply a label depends on the packaging material, and it determines readability.
- Glossy and creasing surfaces: DataMatrix readability can drop on foil and metallised packaging. Moving to series production without a test batch is risky.
- Shelf life and batch data: The batch and expiry data you already keep for food regulation and the batch data on the labelling side must be fed from the same source. A batch number maintained in two separate places produces mismatches directly after 2027.
- Volume economics: High volume, low unit price. Per-code cost looks small but decides the budget at a million units; we broke down the cost components in a separate article.
Where exporters get stuck most often
- Assuming “our product isn’t in scope”. Scope follows the customs code, not the product name. Biscuits and wafers entered scope four months before chocolate.
- Leaving registration to the Russian buyer. Your buyer being registered does not remove your own obligation; these are separate roles.
- Leaving UKEP to the last minute. Nothing can be done in the system without an electronic signature; we set out the process step by step in our UKEP article.
- Incomplete product cards. Missing fields in the National Catalogue card do not block code ordering but do block transfer reporting. We separated GTIN from the customs code in this article.
- Skipping the test batch. The code is printed but does not scan — the most frequent and the latest-discovered error in the field.
Preparation checklist
- Compare the customs codes of all your SKUs against the current scope list.
- Put packaging type and shelf life in writing, product by product.
- Complete company registration, UKEP and EDO; if anything is missing, start here.
- Prepare the National Catalogue product card and GTIN for every SKU.
- Validate your printing or labelling method for your packaging material with a test batch.
- Tie the system that generates batch numbers to a single source — this is the heart of 2027 readiness.
- Check what a code in your hand actually returns using our free code lookup tool.
Frequently asked questions
Are biscuits and wafers in scope?
Yes. According to the timetable reported in publicly available sources, biscuits, wafers, marmalade and Turkish delight entered scope on 1 March 2026 — four months before chocolate. Confirm your own product via its customs code.
Does labelling start in 2027?
No, and this is a common misunderstanding. Labelling itself came into force during 2026 in three stages. What changes in 2027 and 2028 is how closely the code is tracked through documentation.
Is unpackaged, same-day fresh production in scope?
In the baked goods group the obligation is assessed together with consumer packaging and a shelf life longer than 30 days. Products destined for export generally meet that condition and fall in scope.
Should we label in Türkiye or in Russia?
Both may be possible, but labelling before customs reduces risk at the border. The decision should follow your packaging type, volume and logistics setup.
What happens if a shipment is non-compliant?
A product with a missing or incorrect code cannot be sold in Russia, waits at goods receipt and creates administrative exposure. We covered the framework in our penalties guide.
Get ready with Global Znak Consulting
Confectionery and baked goods are among the highest-volume and least forgiving categories in Russian labelling. Scope was completed in 2026; 2027 and 2028 bring documentary discipline. Companies that plan the transition turn it into routine; those that leave it late turn it into a recurring shipment crisis.
With offices in Moscow, Istanbul and Podgorica, and as a member of the Turkish-Russian Businessmen’s Association (RTİB), we have been in Russia trade since 2004. We manage the process end to end — from scope checks and code generation to the labelling method that suits your packaging and EDO integration. Review our labelling packages or get in touch for a free initial assessment.
Related guides: Russia’s QR code explained · All Russia labelling guides
Disclaimer: The dates and scope information in this article are compiled from publicly available sources and may change during the year. Confirm the obligation for your own product group before shipping.
