The refusal letter (otkaznoye pismo) is the most underrated document in a seller's stack: you need it precisely when your product "does not need" certification. Let's break down what this document is, when it is enough, when it will not save you and how to get it without extra rounds.
What a refusal letter is
A refusal letter (otkaznoye pismo) is a letter from an accredited certification body confirming that a specific product is not subject to mandatory certification or declaration. In other words, it is not a "permission to sell" but official confirmation that no permit documents are required for this category.
The marketplace needs such a document to close a formality: the platform is not obliged to take the seller's word that their product "is not subject to anything". When moderation or a customer asks for documents, the refusal letter is the short answer to that request.
When a refusal letter is enough
A refusal letter settles the question for products that do not fall under the lists of the technical regulations (TR TS): some decorative and household goods, stationery, some accessories and household supplies. The exact answer never comes from eyeballing the category — it comes from the customs classification code (TN VED): the certification body checks it against the regulation lists and, depending on the result, issues either a refusal letter or a referral to certification or declaration.
The platform may ask for a refusal letter even where the law requires nothing at all: that is its right under the offer agreement. This is why experienced sellers arrange a refusal letter in advance for every "document-free" item, so that a product card does not sit in moderation in peak season.
When a refusal letter will not save you
The main mistake is trying to cover a product that is in fact subject to mandatory conformity assessment with a refusal letter. If the category is on the technical regulation (TR TS) lists — children's goods, clothing in contact with the skin, electronics — a refusal letter will not replace a certificate or a declaration: moderation will reject the document, and a customer complaint will end with the product card taken down and a penalty. How certificates and declarations work is covered in a separate guide on certification for marketplaces.
The second situation where a refusal letter does not work is Chestny Znak labeling: that is a separate system with its own list. A product may need no certificate and still need labeling — check both lists, details are in the guide on Chestny Znak.
The third is branded goods: a rights holder's complaint is answered not with a refusal letter but with brand documents — covered in the guide on documents for branded goods.
How to get a refusal letter
Step 1. Determine the product's customs classification code (TN VED). The body uses it to check whether the product falls under the mandatory assessment lists.
Step 2. Choose a certification body. The register of accredited bodies is on the Rosakkreditatsiya website. Request several quotes and compare turnaround times: the service is standard, but the spread in terms is noticeable.
Step 3. Hand over the product data. Usually a product description, the composition or material, the TN VED code and the seller's details are enough.
Step 4. Get the letter and check the wording. The letter must name the specific products and the applicant — the platform will not accept a "universal" letter issued to someone else's legal entity.
Common mistakes
- Buying a "refusal letter" from a non-accredited outfit. Moderation checks the body against the register: a letter from an organization outside the register is just paper.
- Getting the letter for one set of items and selling another. The document only works for the products listed in it.
- Treating a refusal letter as a permanent indulgence. Regulation lists get updated: a category that "was not subject" yesterday can come under mandatory assessment — recheck every time you expand your range.
The refusal letter is the fastest document in a seller's whole stack. Check the TN VED code, order the letter from a body in the register and close the formality before anyone asks for it.
