Armenia's 2026 Import and Export Ban on Specified Mercury-Added Products

27/10/2026

Effective September 26, 2026, Armenia introduced a six-month restriction on the import and export of specified mercury-added products. The measure was adopted by Government Decision No. 1384-N dated September 24, 2026.

The restrictions are relevant to businesses importing or exporting certain lighting products, measuring instruments, batteries, medical devices, and mercury compounds.

1. What legislation establishes the restriction?

Armenian Government Decision No. 1384-N establishes a list of mercury-added products whose import into Armenia and export from Armenia are prohibited for a six-month period.

The decision entered into force on September 26, 2026.

Important: The restriction applies to the specific categories of products listed in the annex. It does not automatically prohibit every product that might contain mercury.

2. Which products are covered?

Product category	EAEU HS code
Mercury-oxide primary cells and batteries	8506 30 000 0
Mercury lamps	8539 32 200 1
Mercury-containing non-electronic barometers and hygrometers	Ex 9025 80 200 0; Ex 9025 80 800 0
Mercury-containing non-electronic manometers	Ex 9026 20 400 0; Ex 9026 20 800 0
Mercury-containing non-electronic thermometers	Ex 9025 11
Mercury-containing non-electronic blood pressure measuring instruments	Ex 9018 90 100 0
Mercury chloride, mercury dichloride, mercury cyanide and mercury oxycyanide	Ex 2852 10 000 8

Important: The annex specifies that, where a product description conflicts with its EAEU HS code, the code is indicative and the product description takes precedence.

The term "Ex" indicates that only the relevant goods within the broader tariff classification are covered.

3. How is mercury content identified in measuring instruments?

For the non-electronic measuring instruments listed in the decision, mercury content may be identified through:

Information declared in the relevant customs declaration field.
Customs control establishing that the instrument operates using liquid mercury.
Components filled with liquid mercury.
Product labels, packaging, or accompanying documents indicating mercury content.

For example, a modern electronic thermometer should not automatically be treated as a mercury thermometer merely because both instruments measure temperature.

4. Are there any exemptions?

The decision provides exemptions for specified purposes where the importer or exporter has prepared and approved a written declaration confirming the necessity of the product for:

Civil protection.
Military purposes.
Research, including medical research.
Instrument calibration.
Use as a reference standard.

The declaration must be available during the relevant customs procedure.

The restriction also does not apply to goods placed under the customs transit procedure.

5. What should importers check before shipping?

The exact product description and intended use.
Manufacturer, model, and technical specifications.
Whether the product contains mercury.
The correct EAEU HS classification.
Whether the product falls within the list in Decision No. 1384-N.
Whether an exemption may apply and the required written declaration is available.
Whether the decision has been amended before the shipment date.

Where necessary, importers should obtain technical data sheets or manufacturer documentation confirming the product's material composition.

6. What risks may arise during customs clearance?

Where a product falls within the prohibited list and no exemption applies, normal import or export customs clearance may not be possible.

Missing technical information or inconsistent documents may also lead to additional checks and delays.

Product eligibility should therefore be verified before payment and shipment.

7. REGULUS GROUP recommendations

Businesses planning to import or export measuring instruments, lamps, batteries, or mercury compounds should review the product specifications and applicable legal restrictions in advance.

REGULUS GROUP assists businesses with document reviews, EAEU HS classification, import restriction assessments, customs consultation, and customs clearance services in Armenia.