The situation on the market of automobile spare parts and electronics in Russia has undergone dramatic changes, and the mechanism has become a key tool for adaptation parallel import. It is critically important for participants in foreign economic activity (FEA) and car service owners to understand what goods can be imported without the consent of the copyright holder. Exactly Ministry of Industry and Trade forms and regularly updates a list of such goods, based on HS codes.
In current conditions, the lack of up-to-date information from the list can lead to cargo delays at customs, fines, or even confiscation of goods. Without inclusion of the product code in the current list of the Ministry of Industry and Trade, import without the permission of the copyright holder is considered counterfeit with all the ensuing legal consequences. Therefore, regular checking of the database is a mandatory procedure before concluding contracts with foreign suppliers.
In this article we will analyze in detail the structure of the official list, algorithms for checking codes and nuances that logistics companies are often silent about. You will learn how to properly classify automotive components and why the old lists no longer work. This guide will help you minimize risks when importing spare parts necessary for car repair and maintenance.
Legal basis for parallel imports into the Russian Federation
The parallel import mechanism was launched by the government of the Russian Federation as a response to sanctions pressure and the withdrawal of a number of brands from the market. Decree of the Government of the Russian Federation No. 506 became the foundation that allowed the import of original products without the consent of the copyright holder. This is not the legalization of counterfeit goods, but the creation of a legal channel for the supply of original goods through third countries.
This has been a lifesaver for the automotive industry, as the sector's dependence on imported components auto electricians and engine manufacturing remains colossal. The state takes on the function of a regulator, determining which goods are in short supply allowing this mechanism to be launched. The list is not static: it changes depending on the fullness of store shelves and dealer warehouses.
⚠️ Attention: Importing goods that are not on the current list of the Ministry of Industry and Trade, without the permission of the copyright holder, is equivalent to a violation of intellectual rights. Customs authorities have every right to seize such cargo.
It is important to understand that the authorization is valid only for a certain period and can be revoked at any time if the copyright holder resumes official deliveries. Therefore, businesses need to constantly monitor legislative acts. The legal purity of the transaction depends on the date of arrival of the goods and the effective date of the relevant ministry order.
Structure and content of the list of the Ministry of Industry and Trade
The official document is a table where the main identifier is the code Commodity Nomenclature of Foreign Economic Activity of the EAEU (Commodity nomenclature of foreign economic activity). It is based on these codes that the customs inspector makes a decision on whether to allow the cargo to pass through. The list contains not only codes, but also, in some cases, specific brands or models, although grouping by product items is most often used.
For automotive topics, the most relevant sections are those related to spare parts, components and assemblies. Particular attention should be paid to codes starting with groups 84, 85 and 87. This includes engines, transmission components, body parts and complex electronics. Errors in the classification of goods during (declaration) can be very expensive.
Below is a table with examples of HS codes that often appear in lists for parallel import of auto components:
| HS Code | Product item description | Product examples |
|---|---|---|
| 8409 91 000 0 | Parts intended exclusively or mainly for engines | Pistons, rings, liners |
| 8507 20 000 0 | Lead batteries | Starter batteries for cars |
| 8708 30 910 0 | Brakes and their parts for passenger cars | Brake discs, calipers |
| 8512 20 000 0 | Other electrical lighting equipment | Headlights, turn signals, LED blocks |
Each code in the list has its own specific description. For example, for electronic control units (ECU) Different codes may be used depending on their function. If your product does not exactly match the description in the “Description” column, customs may request additional examination. Therefore, reconciliation with the base should be millimeter-by-millimeter.
Algorithm for checking the relevance of the HS code
The verification process begins long before the goods are shipped to a warehouse in China, Turkey or the UAE. The first step is to accurately identify the product. You need to obtain technical documentation from the supplier, which indicates the purpose, composition and characteristics of the part. Based on this data, the HS code is selected.
Next comes the stage of reconciliation with the current order of the Ministry of Industry and Trade. Lists are published on official resources and in legal databases. It is important to look for the latest version of the document, as previous versions are no longer valid. Changes are often made “quietly”, without loud press releases, so relying on old memos from logisticians is unacceptable.
- 🔍 Request from the supplier a complete technical data sheet of the product indicating the material and function.
- 📄 Select the TN VED code using a reference book or the services of a customs broker.
- 🖥️ Check the availability of the code in the latest published list of the Ministry of Industry and Trade.
- 📅 Make sure that the contract and shipment date falls within the validity period of the order.
If the code is found in the list, you can proceed to complete the transaction. However, if the product is complex and composite (for example, engine assembly), a preliminary classification decision may be required. In such cases, it is better not to take risks and turn to professionals to obtain an official opinion.
☑️ Check before importing auto parts
Specifics of import of auto parts and electronics
The automotive sector is one of the largest in terms of the number of items on the list of parallel imports. This is due to the fact that the production of many models in the Russian Federation has been stopped, and the car fleet is aging and requires maintenance. The greatest demand is for consumables and items subject to wear.
A separate category is auto electronics. Control units, multimedia systems, parking sensors - all these are high-tech components that are often supplied only by official dealers. In conditions of parallel import, these goods go through third countries, which increases their final cost, but ensures availability on the market.
⚠️ Attention: When importing electronics, pay attention to certification. Parallel imports do not eliminate the need to obtain declarations of conformity or safety certificates (for example, according to the technical regulations of the EAEU).
It's also worth noting the compatibility issue. When ordering spare parts by catalog numbers through parallel import, there is a risk of receiving a part intended for a different market (for example, with different environmental standards or interface language). Firmware of blocks may require additional time and equipment to adapt to Russian realities.
Risks when importing electronics
When importing automotive electronics, there is a risk of incompatibility of frequencies of radio modules or lack of Russification of the interface. In addition, some blocks may be tied to the VIN code of the donor vehicle, which will require a complex adaptation procedure or replacement of chips.
Customs clearance and document flow
The process of customs clearance of goods imported as part of parallel imports has its own characteristics. The main document confirming the legality of import is the declaration of goods (DT), where the relevant codes are indicated in the transaction specifics column. The customs inspector will definitely check the presence of the product code in the list of the Ministry of Industry and Trade on the date of registration of the declaration.
Document flow must be perfect. The chain of contracts from the final buyer to the foreign manufacturer must be traced. If you are importing original spare parts BMW or Toyota through an intermediary in Kyrgyzstan, you must have in your hands a full package of documents confirming the legality of purchasing the goods in the transit country.
It is important to correctly fill out column 44 of the DT, indicating the number and date of the order of the Ministry of Industry and Trade. Errors in numbering may lead to suspension of product release. In addition, you must pay all applicable customs duties and fees, which are calculated from the customs value of the goods.
Keep all correspondence with the supplier and invoices in electronic form for 3 years. Customs authorities can initiate a post-customs audit, and the lack of primary documents will lead to additional charges and fines.
Common mistakes and ways to avoid them
One of the most common mistakes is the use of HS codes from old versions of the list. Businesses often find a PDF file from six months ago and work from it, not knowing that a specific item has been excluded. This leads to situations where the cargo is already on the way, but it cannot be imported according to the old rules.
Another mistake is incorrect classification of goods for the sake of a lower duty or simplification of the procedure. Customs has the right to conduct an examination and reclassify the goods, which will entail fines and penalties. For example, an attempt to carry out internal combustion engine as “engine parts” may be regarded as an unreliable declaration.
- 🚫 Ignoring legislative updates (monitor the Ministry of Industry and Trade website weekly).
- 🚫 Hope for "maybe" when classifying complex nodes.
- 🚫 Lack of verification of the counterparty in the transit country.
To avoid these pitfalls, create an internal procedure for checking each new item. Implement a “double check” rule: one employee selects the code, the second checks it with the database. It will take time, but it will save money and the company's reputation.
Key Takeaway: Parallel imports are a temporary measure with strict regulation. Success depends on your attention to detail and prompt updating of information.
Prospects and forecasts for the development of the mechanism
Experts agree that the parallel import mechanism will continue to operate for a long time until new production chains are established or logistics routes with departed brands are completely restored. However, the list of products will narrow as the market becomes saturated or localization expands.
For the auto business, this means the need for flexibility. Today you can freely import turbines and injectors, and after six months these positions may be closed for parallel imports if the copyright holder decides to return. Or vice versa - the list will expand to new product groups.
In the long term, a transition is expected from the chaotic import of “whatever” to structured deliveries through authorized importers, even if the brand has not formally returned to the country. The state will strive to control the quality of imported spare parts in order to protect consumers from low-quality analogues.
How often is the Ministry of Industry and Trade list updated?
The list does not have a fixed update schedule. Orders may be issued several times a month or may not be issued for several months. It all depends on the economic situation and business needs. It is recommended to check the database at least once every two weeks before making purchase plans.
Is it possible to import entire cars through parallel import?
Yes, passenger cars are also included in the list of goods for parallel import. However, they are subject to special recycling fee requirements. If a vehicle is imported for resale, the salvage tax rate may be significantly higher than for personal use, making commercial importation less profitable without careful calculation.
What should I do if the product code has disappeared from the list?
If the code is removed from the list after you have entered into a contract but before the goods arrive, the situation is complex. You need to either obtain permission from the copyright holder (which is almost impossible for sanctioned brands), or look for alternative ways (for example, changing the HS code if there are grounds, if the product can be classified differently), or be prepared to refuse to release the product.
Does parallel import apply to used spare parts?
The parallel import mechanism primarily concerns new goods. The import of used auto parts (contract) is regulated by other regulations, in particular, requirements for their condition and prohibitions on the import of certain categories of waste. However, if a used part is classified as a product item permitted for parallel import, this is theoretically possible, but requires careful verification of the customs value.