📰 Liability for selling products without an SGR
A Certificate of State Registration (SGR) is mandatory for products that affect human health, including food, cosmetics, chemicals, children’s products and other categories.
Selling products without an SGR constitutes an administrative offense and can have serious consequences, ranging from fines to confiscation and suspension of business activities.
⚖️ Why is having an SGR mandatory?
In Kazakhstan and the EAEU, only products that have passed safety checks and been registered in accordance with sanitary and hygienic standards may be sold.
An SGR confirms that a product:
- is safe for human health;
- meets sanitary, hygienic and epidemiological requirements;
- is included in the official EAEU register.
The absence of a certificate means that the product has not passed state control and may pose a potential danger.
🧾 Regulatory framework
Liability for selling goods without an SGR is established by:
- the Code of the Republic of Kazakhstan on Administrative Offenses,
- Article 425, “Violation of Sanitary Rules”, and Article 462, “Violation of Technical Regulation Requirements”;
- the Law of the Republic of Kazakhstan “On the Sanitary and Epidemiological Well-being of the Population”;
- Decision No. 299 of the Customs Union Commission, “On the Application of Sanitary Measures”.
💰 Penalties and fines
1. Fines
The amount of the fine depends on the category of the offender (individual, entrepreneur, or organization) and the degree of danger of the product.
- for individuals — from 15 to 50 MCI;
- for individual entrepreneurs — from 100 to 500 MCI;
- for legal entities — from 500 to 1,000 MCI.
📌 MCI stands for monthly calculation index (KZT 3,932 in 2025).
Thus, the fine for the company can reach 3-4 million tenge for one batch of goods.
2. Confiscation of products
Goods without an SGR are subject to withdrawal from circulation and destruction by decision of the regulatory authorities.
Confiscation is carried out regardless of whether the goods have been sold or are in a warehouse.
3. Suspension of activities
In case of repeated violations or systematic sale of unregistered products, supervisory authorities may:
- suspend the company’s activities for up to three months;
- revoke its license to manufacture or sell goods;
- enter the company in the register of unreliable suppliers.
🚨 Examples of situations where fines are imposed
- An importer brought in cosmetic products without obtaining an SGR. The consignment was detained during a customs inspection and returned to the sender.
- A dietary supplement manufacturer had not completed state registration. When its products were sold through a pharmacy chain, the manufacturer received a fine of 750 MCI and an order to stop sales.
- An online store sold household chemicals without an SGR. Its website was temporarily blocked and the goods were confiscated.
📋 How to avoid fines
To avoid administrative liability, you must:
- Check whether your product is included in the list of products subject to state registration (Decision No. 299).
- Consult specialists about the EAEU commodity code (TN VED), as this determines whether an SGR is required.
- Obtain the certificate in good time through an accredited body.
- Make sure the SGR is entered in the EAEU Unified Register so that it can be verified online.
🧩 How ALMA TEST helps avoid violations
ALMA TEST provides a complete service for obtaining an SGR:
- analysis of your products and determination of the need for state registration;
- preparation and verification of documents;
- organization of laboratory tests;
- support until the certificate is received and entered into the register.
Thanks to official accreditation and experience working with sanitary control authorities, we help avoid any claims and fines during inspections.
✅ Summary
Selling goods without a Certificate of State Registration (SGR) is more than a procedural violation: it poses a risk to the business.
Failure to obtain an SGR can result in substantial fines, confiscation of products and suspension of business activities.
Obtaining the document through a professional company such as ALMA TEST ensures safety, legal compliance and confidence in every product consignment.