When importing goods into Armenia or exporting goods from Armenia, a commercial invoice, shipping documents, and a customs declaration may not always be sufficient. Certain categories of goods are subject to non-tariff regulatory measures that may require an import or export license, permit, authorization, or registered notification.
Before entering into an international trade transaction, businesses should determine whether their goods are subject to restrictions and identify the competent Armenian authority responsible for the relevant sector.
Two important legal sources are Eurasian Economic Commission Board Decision No. 30 of April 21, 2015, on non-tariff regulation, and Armenian Government Decision No. 1524-N of December 25, 2014.
Non-tariff regulation covers measures governing international trade other than ordinary customs tariffs and taxes.
Article 46 of the Treaty on the Eurasian Economic Union provides for several measures in trade with third countries:
These measures may protect public health, the environment, cultural heritage, security, or other legitimate public interests.
A prohibition is different from a restriction. Where imports are prohibited, obtaining an ordinary license does not automatically make the goods admissible. Where an authorization procedure applies, a transaction may be permitted if the relevant conditions are satisfied.
EEC Board Decision No. 30 of April 21, 2015, establishes the principal common non-tariff regulation measures applied to trade between the EAEU and third countries.
The decision provides for:
This decision helps businesses identify the applicable trade restrictions and determine the relevant import or export procedures.
Armenian Government Decision No. 1524-N of December 25, 2014, establishes national lists of relevant product categories, identifies competent government authorities, and sets out a framework for issuing import and export licenses and permits.
Its principal annexes are:
Annex No. 3 is particularly useful to businesses because it identifies which Armenian state authority is responsible for the relevant product category.
The following examples are based on Annex No. 3 to Armenian Government Decision No. 1524-N.
| Product category | Responsible Armenian authority |
|---|---|
| Medicines and pharmaceutical substances | Ministry of Health |
| Narcotic drugs, psychotropic substances, and their precursors | Ministry of Health |
| Plant protection products (pesticides) | Ministry of Economy |
| Precious stones, precious metals, and relevant raw materials | Ministry of Economy |
| Ozone-depleting substances | Ministry of Environment |
| Hazardous waste | Ministry of Environment |
| Wild animal and plant species subject to CITES controls | Ministry of Environment |
| Certain civilian radio-electronic and high-frequency devices | Ministry of High-Tech Industry |
| Encryption equipment and special technical devices intended for covert information collection | National Security Service |
| Cultural property and relevant archival documents | Ministry of Education, Science, Culture and Sports |
| Specified categories of mineral raw materials | Ministry of Territorial Administration and Infrastructure |
| Human organs, tissues, blood, and certain biological material samples | Ministry of Health |
Important: This table is not the complete list under Annex No. 3. It identifies the authorities coordinating the relevant sectors, rather than guaranteeing that every product in a category requires the same document.
For each transaction, the applicable import or export direction, product characteristics, legal requirements, and exemptions must be checked.
A license authorizes the import or export of specified goods under the conditions established by the relevant legislation. Depending on the applicable framework, single, general, or exclusive licenses may be available.
Under the framework established by Decision No. 1524-N, a permit is associated with transactions involving products subject to automatic licensing or monitoring.
In certain cases established by the Eurasian Economic Commission, an authorization document grants the right to import or export the relevant goods.
Some product categories may be subject to notification registration rather than an ordinary licensing procedure.
Important: The term "import permit" is frequently used as a general expression. The legally required document may instead be a license, an authorization, or a registered notification.
A company planning to import plant protection products into Armenia from a third country should examine the product's composition, EAEU HS classification, and applicable restrictions.
Annex No. 3 to Decision No. 1524-N identifies the Ministry of Economy as the authority responsible for this sector. The precise documentation requirements must be established under the applicable product-specific regulations.
For certain radio-electronic and high-frequency devices, importers should review technical specifications, operating frequencies, intended use, and the applicable product lists.
The Ministry of High-Tech Industry is identified as the responsible authority for the relevant sector. This does not mean that every electronic device automatically requires the same authorization.
Before exporting cultural property or relevant archival materials from Armenia, businesses should verify the applicable restrictions and documentation requirements.
The responsible authority for this sector is the Ministry of Education, Science, Culture and Sports.
Annex No. 4 to Decision No. 1524-N provides for electronic applications through Armenia's National Single Window for Foreign Trade.
Depending on the type of goods and document, an application may require applicant identification, product details, supporting records, information on state fees, and additional documents prescribed by sector-specific regulations.
The general framework provides for certain application processing deadlines, but these should not be interpreted as a guarantee that every type of license or permit will always be issued within one working day.
This is a practical preliminary review checklist, not a universal statutory document list for every shipment.
No. A permit or license requirement must be established by an applicable legal rule.
Even when goods fall within a broadly regulated sector, businesses must examine the precise product description, classification, applicable restrictions, and any exemptions.
Furthermore, the regulations discussed in this article primarily concern trade between the EAEU and third countries. Different rules may apply to movements between EAEU member states and to veterinary, phytosanitary, sanitary, or technical conformity requirements.
Non-tariff import and export authorizations therefore do not automatically replace other documents required for a shipment.
Not always. The tariff code must be assessed together with the actual product description and the relevant legal lists.
Supplier information can be useful but does not replace a review of Armenian and EAEU legal requirements.
The conditions for obtaining the required document and completing customs clearance should be reviewed in advance. Delayed applications may result in additional expenses and clearance delays.
Measures established for trade with third countries should not automatically be applied to all movements between EAEU member states. The specific legal position and any other applicable restrictions must be checked separately.
Import and export compliance should be assessed before a purchase is finalized or goods are shipped.
REGULUS GROUP assists importers and exporters with preliminary product reviews, EAEU HS classification, regulatory restrictions, coordination of necessary authorization documents, customs consultations, and customs clearance services in Armenia.
Correct product classification, identification of the responsible authority, and early documentation checks help businesses reduce compliance risks and avoid unnecessary clearance delays.
Importers and exporters should verify the current legal texts and product-specific requirements before each transaction.