If there is a notification, then the license of the Ministry of Industry and Trade is not needed
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Friends, if there is a notification, then the license of the Ministry of Industry and Trade is not needed! It is such a phrase that you can hear from the gods of Certification, but what is there, even experienced brokers, constantly make such a mistake.
It would seem that what is the mistake here?
According to decision 30 (Decision of the Board of the Eurasian Economic Commission of 21.04.2015) p. 2. 19 (Encryption (cryptographic) means) there are two mutually exclusive documents Notification and License of the Ministry of Industry and Trade. After all, everyone is right!
And the error lies in the context. If we speak within the framework of paragraph 2. 19, the phrase sounds correct, BUT when we hear such a phrase (in 100/100 cases), we mean a notification under paragraph 2. 19, and a license of the Ministry of Industry and Trade under paragraph 2.16 (Radio-electronic means and (or) high-frequency devices). In this context, this phrase does not work and leads directly to the "protocol". Why?
Let's figure it out:
1. Solution 30 is one, but it is necessary to separate p. 2. 16 and p. 2. 19. These are two different areas of legislation, different authorized bodies, different procedures for notification/confirmation of compliance, the only thing they are similar in is the possibility of obtaining a license from the Ministry of Industry and Trade. You can get a license there and there, but the grounds for issuing a license are completely different!
2. We have repeatedly said that radio electronics is one of the most complex product groups and it has many faces. One device can be assigned different HS codes and the same device can have both cryptographic functions and radio transmitting elements. In other words, it falls under paragraph 2. 19 and paragraph 2.16. And such a device requires registration and notification and registration in the Roskomnadzor register, after which it is necessary to obtain a license from the Ministry of Industry and Trade, the basis for which will simultaneously serve as a notification and an extract from the Roskomnadzor register.
3. Companies that receive a license from the Ministry of Industry and Trade under clause 2.19 (cryptography) and for whom this rule works, you can count on the fingers of 10 hands. There are very few of them and they clearly know what they are doing!
Therefore, in 95% of cases, you should not rely on the rule "If there is a notification, then the license of the Ministry of Industry and Trade is not needed!", but it is better to turn to professionals for advice!
By the way, our company has been engaged in the import/export of electronics and radio electronics for more than 10 years and knows about licenses and notifications-everything!
We are in social networks:
Have a question? Call 8 499 647-75-64 or write info@notifikat.ru
Friends, if there is a notification, then the license of the Ministry of Industry and Trade is not needed! It is such a phrase that you can hear from the gods of Certification, but what is there, even experienced brokers, constantly make such a mistake.
It would seem that what is the mistake here?
According to decision 30 (Decision of the Board of the Eurasian Economic Commission of 21.04.2015) p. 2. 19 (Encryption (cryptographic) means) there are two mutually exclusive documents Notification and License of the Ministry of Industry and Trade. After all, everyone is right!
And the error lies in the context. If we speak within the framework of paragraph 2. 19, the phrase sounds correct, BUT when we hear such a phrase (in 100/100 cases), we mean a notification under paragraph 2. 19, and a license of the Ministry of Industry and Trade under paragraph 2.16 (Radio-electronic means and (or) high-frequency devices). In this context, this phrase does not work and leads directly to the "protocol". Why?
Let's figure it out:
1. Solution 30 is one, but it is necessary to separate p. 2. 16 and p. 2. 19. These are two different areas of legislation, different authorized bodies, different procedures for notification/confirmation of compliance, the only thing they are similar in is the possibility of obtaining a license from the Ministry of Industry and Trade. You can get a license there and there, but the grounds for issuing a license are completely different!
2. We have repeatedly said that radio electronics is one of the most complex product groups and it has many faces. One device can be assigned different HS codes and the same device can have both cryptographic functions and radio transmitting elements. In other words, it falls under paragraph 2. 19 and paragraph 2.16. And such a device requires registration and notification and registration in the Roskomnadzor register, after which it is necessary to obtain a license from the Ministry of Industry and Trade, the basis for which will simultaneously serve as a notification and an extract from the Roskomnadzor register.
3. Companies that receive a license from the Ministry of Industry and Trade under clause 2.19 (cryptography) and for whom this rule works, you can count on the fingers of 10 hands. There are very few of them and they clearly know what they are doing!
Therefore, in 95% of cases, you should not rely on the rule "If there is a notification, then the license of the Ministry of Industry and Trade is not needed!", but it is better to turn to professionals for advice!
By the way, our company has been engaged in the import/export of electronics and radio electronics for more than 10 years and knows about licenses and notifications-everything!
We are in social networks:
Have a question? Call 8 499 647-75-64 or write info@notifikat.ru