WWBridge overview of main requirements, applied products, procedures and timing to get the FSS Notification for encryption means.
All products that are capable of encryption need to be approved in the Federal Security Service (FSS or sometimes called FSB) in order to be successfully imported to the Customs union. A special document that confirms the product which is transfer data through crypto algorithms can be imported is called FSS Notification (or FSB Notification).
All products that must be approved through FSS mentioned in the List of encryption means (article 2.19 of the «Non-tariff regulated product list»).
This List includes the following product groups:
So, any of modern telecommunication devise such as mobile phone, laptop, tablets and other that use wireless data transfer technologies such as Wi-Fi, Bluetooth, GSM, GPRS, GLONASS, can be classified as one of the mentioned product group and requested the FSS Notification while Customs clearance.
Before July 2018 the main defining characteristic that determined whether it is necessary to get FSS approval or not, was the ability of the device to encrypt the data. Now, we should also take into consideration The list of encryption means above. Which means that if the product is capable of encryption but can not be classified as one of the means from the List the FSS Notification is not required.
Instead, the FSS Exemption letter will be issued that can be used as an evidence while importing the goods.
The process of the applying for the FSS notification as such as for the FSS exemption letter takes 10 working days.
Before the manufacturer should prepare the legalized Power of Attorney for his partner in the Russian Federation – a resident legal entity which can apply to the FSS for the Notification.
Under legalization power of attorney apostille or the seal of the Russian consul is meant. The power of attorney shall be done by the manufacturer at the local notary office. After this, a notarized power of attorney is transmitted to the Russian consulate (to prove the seal, signature of the notary, who had previously assured the power of attorney) in the country of the manufacturer or, if the country is included in the Hague Convention, for apostille instead of consulate seal.
In order to successfully obtain a notification of the Federal Security Service of the Russian Federation, an apostilled power of attorney should meet the following requirements:
The notary public must attest that:
There are also a set of requirements to the form of these document.
We help to obtain the PoA, preparing the draft, making recommendations and providing the notary translation of the seal/apostille into the Russian language. WorldWideBridge LLC can also act as a Local representative and apply to FSS.
We will be pleased to consult you.
To receive the final conclusion on the necessity of issuing the FSS Notification.
Looking forward to receiving your inquiries.