What Happened
Changes have been made to the list of international and regional (interstate) standards, and in their absence — national (state) standards, the application of which ensures compliance with the requirements of the technical regulation of the Customs Union "On Food Safety" (TR CU 021/2011) on a voluntary basis.
This concerns the so-called evidential list: a list of standards whose application helps the manufacturer or importer confirm that the food products meet the mandatory requirements of the regulation. Updating such lists is a regular procedure within the EAEU: outdated standards are excluded, while new and updated ones are included to ensure the list reflects the current regulatory and technical framework.
Who It Affects
The changes affect a wide range of participants in the food market in Kazakhstan and other countries of the Union:
- food product manufacturers — those who release goods into circulation and confirm their safety;
- importers and distributors bringing food products into the EAEU territory;
- certification bodies and testing laboratories that refer to standards when assessing compliance;
- quality specialists, technologists, and lawyers involved in the production and circulation of products.
If your activities are related to the production, import, or compliance assessment of food products, the update of the list directly affects which standards you are entitled to follow to confirm safety.
What It Means in Practice
Including a standard in the list means that its voluntary application is considered sufficient to meet the relevant requirements of the regulation — this simplifies the evidential basis for declaration and certification. Excluding a standard means that it can no longer be referenced as a tool for presumption of compliance; in this case, compliance must be confirmed by other means — for example, by other active standards or direct testing according to the regulation's indicators.
It is important to understand: the standards from the list are applied on a voluntary basis. The requirements of the technical regulation TR CU 021/2011 remain mandatory. The list merely records the "safe path" for their implementation — a set of documents whose application is officially recognized as confirmation of compliance.
What to Do
1. Check the current version of the list. Verify which standards have been added and which have been excluded, and how this relates to the products you manufacture or import.
2. Analyze your documentation. Ensure that declarations and certificates of compliance, as well as internal procedures, refer to active, not excluded standards.
3. Update your technical and regulatory framework. If necessary, update references in technological documentation, production control programs, and contracts with laboratories.
4. Coordinate changes with certification bodies and laboratories. Clarify which standards are currently being used for testing your products.
5. Monitor the effective dates of changes and transitional provisions, if established, to avoid gaps in the evidential basis.
A practical approach is to conduct an audit of all active compliance documents and proactively adjust processes to the updated list, without waiting for scheduled inspections.
Frequently Asked Questions
Are the standards from the list mandatory to apply? — No. Their application is voluntary, but it provides a presumption of compliance with the requirements of TR CU 021/2011. The requirements of the regulation itself remain mandatory, and the method of confirming them can be chosen.
What should we do if the standard we referenced has been excluded from the list? — You need to switch to another active standard from the list or confirm compliance directly according to the regulation's indicators through testing. Previously issued documents should be checked for relevance.
Does the update of the list affect already issued declarations and certificates? — Generally, the validity of previously issued documents remains within their term, but when reissuing and for new supplies, it is necessary to rely on the current version of the list. Clarify details with the certification body.
Do these changes only concern Kazakhstan? — No. The list operates within the EAEU framework, so the changes affect market participants in all Union countries, including Kazakhstan.
Where to track the current version of the list? — In the official regulatory sources of the EAEU and national databases of legal and regulatory technical information, as well as through certification bodies and specialized consulting services.
Sources
- On amendments to the list of international and regional (interstate) standards, and in the absence of such, national (state) standards, the application of which ensures compliance with the requirements of the technical regulation of the Customs Union "On Food Safety" (TR CU 021/2011) on a voluntary basis — Adilet (database of regulatory information on taxes and accounting).