Selling into Europe from Central Asia: certification, customs and distributors

The EU is the main export destination for Central Asia, taking almost a third of the region’s exports according to the European Commission. Most of that is oil, gas, metals and cotton fibre. If you make finished goods or food products, selling into Europe means getting three things right: the product rules, customs, and the partner who will sell for you.

Start with the product rules

EU product rules depend on what you sell. Before you price anything or approach a buyer, find out which rules apply to your product. Getting this wrong is the most expensive mistake an exporter can make, because non-compliant goods can be stopped at the border or withdrawn from sale.

There are two broad groups:

• Industrial and consumer products, many of which need CE marking.
• Food, plants and animal products, which follow EU health and safety controls.

Some products fall into neither group and are covered by general EU product safety rules instead. Your Europe points out that products outside the CE marking rules must not carry the CE mark.

CE marking, explained simply

CE marking is the manufacturer’s declaration that a product meets EU rules. Your Europe lists examples of products that need it, including toys, electrical and electronic equipment, machinery, some pressure equipment and gas appliances, batteries, personal protective equipment and medical devices.

The manufacturer is responsible for the whole process:

1. Identify all EU rules that apply to the product.
2. Check whether you can assess conformity yourself or need a notified body, an independent organisation approved by an EU country. Notified bodies can be checked in the EU’s NANDO database.
3. Prepare technical documentation.
4. Sign an EU Declaration of Conformity.
5. Affix the CE mark.

Three points catch exporters out:

• There is no central EU office that issues a “CE certificate”, and voluntary certificates are not valid for CE marking.
• The technical documentation and declaration must be kept for at least 10 years.
• For many CE-marked products, Regulation (EU) 2019/1020 requires an economic operator established in the EU, such as an importer or an authorised representative, to be responsible for the product. Their name and postal address must appear on the product, packaging, parcel or an accompanying document.

Food, plant and animal products

The Commission’s food safety service explains that the EU’s approach to imported food varies by sector:

• Live animals, products of animal origin, and plants and plant products must go through designated border control points, with checks at set frequencies.
• Most food and feed not of animal origin does not face mandatory checks before entry.
• Some non-animal food is temporarily subject to mandatory border controls when a risk has been identified. These products are listed in Regulation (EU) 2019/1793, which the Commission reviews at least every six months.

Dried fruit, nuts and spices from Central Asia are exactly the kind of products where you should check the current list before shipping. Your national food safety authority and your EU importer should know what applies.

Customs: EORI, duties and origin

EORI number. Anyone lodging customs declarations in the EU needs an EORI number. The Commission explains that a company with no EU establishment applies in the EU country where it carries out its first customs operation. If your EU importer clears the goods, its EORI is used instead.

Duties. The import duty depends on the product’s customs code and its origin. The Commission’s Access2Markets portal and its My Trade Assistant tool show the duty and the rules for each product and market.

Rules of origin. Preferential (lower) tariffs only apply if the product meets the rules of origin for that arrangement. Access2Markets explains that each arrangement has its own rules, and covers proof of origin, including the REX registered exporter system.

GSP+ for Uzbekistan and Kyrgyzstan. Under the EU’s Generalised Scheme of Preferences, Uzbekistan became a GSP+ beneficiary, with preferential tariffs applying from 10 April 2021. The Commission says GSP+ removes tariffs on about two thirds of the product lines covered by the GSP scheme. Kyrgyzstan also benefits from GSP+. Tajikistan meets the standard GSP criteria. Kazakh exporters should check their own tariff position product by product. GSP+ status depends on continued implementation of 27 international conventions, and the EU monitors this, so check the current position in Access2Markets.

Choosing and working with a distributor

Most Central Asian exporters start in Europe with a distributor or importer rather than their own company. A good distributor:

• acts as the importer and handles customs clearance
• can take on the EU economic operator role for compliance
• knows the buyers in its market and sector
• carries stock and manages local delivery

In return, expect them to ask for exclusivity in a territory, marketing support, reliable supply, and documentation that proves your product is compliant. Have your technical file, certificates of origin and product information ready, ideally in English and the language of the target market.

Agree in writing who is responsible for compliance, labelling, returns and product recalls. These questions matter far more in the EU than many exporters expect.

Sanctions and compliance checks

European distributors, banks, insurers and freight companies will screen you before working with you. The UK government’s sanctions guidance for Uzbek businesses explains why: Russia has tried to obtain restricted goods through third countries, and businesses that cannot show they have controls in place may find suppliers and banks unwilling to work with them.

Expect to be asked about your ownership, your other customers and the end use of goods. Keep your ownership records current and screen your own counterparties against the EU, UK and UN sanctions lists. Being ready for these questions makes you a stronger partner.

How Mavericks Go helps

Mavericks Go helps Central Asian producers and manufacturers enter Europe and the UK, with a market briefing and entry plan, introductions to distributors and buyers through Mavericks Connect, and support after you land. Every Go deal is screened against EU sanctions, and legal and compliance work is handled by regulated partner firms.