White delivery or cargo — how we assess import risks in 2026

In September–October 2025, queues of trucks with cargo from China emerged at the Russian-Kazakh border. Market participants reported estimates of up to 10,000 trucks and waiting times of up to a week. On October 24, Decree No. 778 was issued, introducing a temporary procedure for the import and subsequent clearance of certain goods through Kazakhstan and Kyrgyzstan. For those using gray cargo services, such a traffic jam ends not with a delay, but with the risk of goods being seized. With enhanced control, cargo without documents has nowhere to go. We have been transporting containers and consolidated cargo from China for fourteen years and are included in the register of customs representatives of the Federal Customs Service. Further on, we will discuss the differences between white delivery and cargo services, what happened to parallel imports, and why the economics of gray schemes no longer add up. You will do the calculations, and we will provide the figures and calculation procedure.

Why we don't work with gray schemes

We do not work with gray import schemes. The customs representative is jointly liable with the declarant for customs duties within the limits established by law. If the invoice understates the price, additional charges and other amounts provided by law may affect both parties. We do not take on such risk for the sake of saving on duties.

For the same reason, we do not route cargo through front companies in other EAEU countries or split commercial batches into personal shipments. Below, we will analyze these schemes as market practices, not as services offered by our company.

A one-time supply of a small batch is a separate situation. If you are testing a niche with a shipment worth two hundred thousand rubles, not selling goods through marketplaces, and not planning regular shipments, this is a different scale and risk profile. Such shipments are evaluated separately. Further, we will talk about those who regularly transport goods from China.

How cargo services work and where they came from

Cargo is a colloquial term for gray import schemes, not a legal term. Goods cross the border without a full declaration in the name of the final recipient. There are three ways to set up such a scheme. They understate the customs value in the invoice, putting three dollars per unit instead of the actual ten. They split a commercial batch into shipments, trying to declare them as goods for personal use: a weight of up to 31 kg is not enough — cost, purpose, and other conditions of import are also taken into account. Or they route the cargo through a company in Kazakhstan, Armenia, Belarus, and rely on the single customs territory regime. But the route itself does not make Chinese goods duty-free or replace customs clearance.

Until 2022, the logic was simple. According to market participants, gray cargo was 30–50% cheaper than white delivery due to unpaid fees, primarily import VAT — then 20%, and from January 1, 2026, the base rate is 22% — duties (for most codes 0–15%, for some positions higher), and excises where applicable. In a rough calculation for a shipment with a factured value of 10 million rubles, honest customs clearance added 2.5–4 million on top. The exact amount depends on the FEAC code, the composition of payments, and supply terms. For small businesses, this was a deciding factor on whether to proceed or not.

In February 2022, direct supplies of hundreds of Western brands were disrupted, and demand for gray channels surged. Importers who had worked officially turned to cargo services to bring ушедшие brands bypassing distributors. By the end of 2022, the volume of imports of brands without the правообладателя's consent exceeded 20 billion dollars, with peak months exceeding 2.5 billion. Some were cleared through white customs procedures according to the Minpromtorg list, others went through cargo without declarations.

Cargo did not rely on customs blindness. Digital control had not yet been integrated into a single system. Since 2023, this has changed, and we will show how exactly further on.

White delivery — what the procedure consists of

White delivery is also a market label. At customs, it is ordinary import under the EAEU Customs Code. The declarant submits a declaration, pays all duties, and receives a full set of documents.

What the procedure consists of.

• Foreign trade contract with the supplier: specification, unit price, total amount, delivery terms under Incoterms. Required for currency control, and the payment amount must match the contract and invoice.
• The supplier's invoice sets the price. Customs compares this price with the customs value index (CVI) for your FEAC code.
• Customs value declaration (CVD-1 or CVD-2) justifies the declared price. Method 1 is based on the transaction price plus delivery to the border; if the inspector does not accept it, the declaration goes for adjustment.
• Goods declaration (GD, commonly known as GTD) completes the procedure. It is submitted by the customs representative through the FEA participant's personal account, and after paying duties and VAT, the inspector puts a release mark.
• Certificates and declarations of conformity under EAEU technical regulations are mandatory for most consumer goods, electronics, children's products, and electrical equipment. Without them, there will be no release.

We collect the full package in 3–5 days for a new supplier and 1–2 days for a familiar one. Release with complete documents and a zero-risk profile takes from two hours to two business days. We check documents more meticulously than any gray intermediary, and this is not about good faith but the same joint liability. If an error in the declaration affects customs duties, liability may be joint within the limits established by law.

In addition to security, the white scheme has financial benefits. Import VAT (22% from January 1, 2026; the base depends on customs value, duties, and other accruals) can be deducted if you are on the general system, the goods are for taxable activities, and the document requirements are met. On the simplified system, VAT can be included in expenses or remain in the cost — it depends on the tax object and chosen regime. Banks can provide import loans under white contracts, including letters of credit, guarantees, and trade financing. The availability of such tools depends on the bank and transaction structure, and without official documentation, obtaining them is usually more difficult.

Parallel import — a legal channel that is narrowing

Parallel import allows the import of goods under a protected brand without the rights holder's consent. In Russia, it was legalized by Government Decree No. 506 of March 29, 2022; the list for applying the mechanism came into force on May 7, 2022. It allowed importing goods from the Minpromtorg list without the rights holder's consent, provided customs and other mandatory requirements are met. The supply channel can be different — from a distributor in a third country to a marketplace — but it does not cancel declaration and control.

After the peak, volumes have fallen. According to the Minpromtorg, in 2025, the mechanism processed 23.1 billion dollars, and in January 2026, the figure dropped to 1 billion — the lowest since its launch. This was announced on February 20, 2026, by Deputy Minister of Industry and Trade Roman Chekushov (RBC). The mechanism continues to operate in 2026, and the Minpromtorg list is updated as the market and Russian production change.

A clarification we often repeat to clients. Parallel import does not legalize gray imports. The right to bring a brand without its consent does not cancel customs obligations. Goods brought through cargo without a declaration remain illegal import, regardless of whether the brand is on the Minpromtorg list or not. The same brand is legal through a white channel but is a violation of the Customs Code through cargo.

What has changed in 2025–2026

Five shifts in two years have перевернули the economics of gray schemes.

The Federal Customs Service uses international data exchange, including with the customs authorities of the PRC, and a risk management system. The volume and composition of such verification depend on the specific goods and project: declared information can be compared with available export data. If a thousand units were exported at twenty dollars, but in Russia, they declared eight per unit, such a discrepancy can be grounds for additional verification.

Concurrently, the risk management system takes into account customs value benchmarks and other indicators by FEAC code. A price significantly different from the risk profile benchmarks can lead to additional control and requests for bank instructions, supplier price lists, and Chinese export declarations.

Since autumn 2025, control at the Kazakh border has intensified, and queues have formed at some points. Market participants reported delays of up to a week and estimated the queue in October at up to 10,000 trucks; specific figures depended on the point and source. On the Russian side, the FCS has also tightened control. A temporary procedure for certain goods was introduced by Decree No. 778.

Gray logistics has become more expensive. According to our estimate, in some directions, border intermediaries, storage during prolonged control, and a risk premium have increased cargo rates by 20–30% in 2024–2025. The result depends on the route, goods, and service composition. For many groups, the difference with the white scheme has narrowed so much that the main price argument for cargo has disappeared.

Post-control remains. Within three years after release, declared information and customs duties can be audited. The goods are already sold, the profit is spent, and a hole in the cash register opens when there is nothing to close it with.

Cargo risks in concrete figures

FCS figures for 2024 leave little room for иллюзий. Over the year, 166,336 administrative cases were initiated, of which 98,022 under Chapter 16 of the Administrative Code, and within this group, 68,701 cases involved smuggling-related offenses (Articles 16.1–16.4). Additionally, 1,914 criminal cases were opened. Fines totaled 3.8 billion rubles, and property worth over 6 billion rubles was transferred to authorized bodies.

Three articles are applied to participants in gray schemes.

• Article 16.2 of the Code of Administrative Offenses penalizes false declaration. Depending on the composition, the fine can range from 50% to 200% of the customs duties payable, and confiscation is possible. Who will be held liable depends on the person's role and the circumstances of the case.
• Article 16.21 of the Code of Administrative Offenses covers the acquisition, storage, transportation and use of illegally imported goods. For legal entities, the fine can range from 50% to 200% of the value of the goods, and confiscation is possible. The buyer's liability does not arise automatically: the fact of acquisition, the status of the goods and the circumstances of the case are important.
• Article 194 of the Criminal Code punishes the evasion of customs duties. In 2024, 301 criminal cases were opened under it. The threshold depends on the category of goods: for most cases, a large amount is over 3 million rubles, an especially large amount is over 9 million; for certain goods, special thresholds of 2 and 6 million apply. Depending on the composition, the punishment may include a fine of up to 500 thousand rubles or imprisonment of up to two years, and for an especially large amount, the term can be up to five years.

Alongside fines, losses accumulate that are usually not included in the estimate.

Marketplaces. Wildberries, Ozon and Yandex Market may request a customs declaration number and other supporting documents, depending on the product, country of origin, supply scheme and requirements of the specific platform. If the documents do not confirm the legality of import, the product card or sales may be restricted. If you are an established seller, such a sales restriction is comparable to business closure.

VAT. Without confirmed import, input VAT is usually not deductible. VAT on sales is calculated according to general rules, and the lack of documents adds customs, tax and penalty risks. The combined effect of non-deductible import VAT, possible additional charges and penalties may exceed the cost of the first shipment.

Banks. Payments for imports without confirmed foreign trade purpose may be subject to control under Federal Law 115: the bank has the right to request documents, refuse a separate transaction, restrict remote servicing or terminate the agreement under the conditions provided by law. Therefore, problematic payments through cargo can lead to loss of access to the current account at the most inopportune moment.

Where “gray” is still considered profitable. These are single test shipments of untested goods, goods with a duty above 15% where the price gap remains large, and small shipments where a broker is not cost-effective. For the first two, we remind you of Article 16.21 and a fine of up to 200% — these calculations do not take into account the likelihood of post-control. For the third, we have a working solution: LCL consolidated cargo, where the costs of a broker are shared between two or three clients.

Official clearance is especially important if the requirements of a specific platform or product category require proof of import, you regularly claim VAT deductions, take out credit lines for working capital, transport goods that require mandatory certification, or if you have already had a recorded violation — FTS may inspect subsequent declarations more rigorously based on risk profile.

How the FTS detects understatement before the truck arrives

Until 2023, the inspector assessed what was on the table, i.e., the paper declaration, invoice, and packing list. Today, by the time the truck reaches the border crossing, the automated risk management system has already processed the declaration.

First, the risk profile is triggered. The system compares the FEAC code, country of origin, cost per kilogram, supplier and recipient with the database of past violations. Any combination that has previously been associated with violations automatically sends the shipment for additional control.

Next, the China database is involved. For shipments from China, export data is requested at the time of declaration submission, and any discrepancy between the Chinese export price and your declared price is immediately visible. Then there is a comparison with the index. If it is below the threshold, requests are made for bank orders, the supplier's price list and the contract.

If the cost is adjusted, you will be offered two options. Either deposit an amount equal to the calculated additional charge and retrieve the goods, or leave the cargo in temporary storage until the dispute is resolved. Storage at the temporary storage facility is at your expense, and while you are looking for available working capital for the deposit, the goods are in the temporary storage facility and become more expensive every day.

The amount saved by understating will be added after the goods are sold — that is, at the moment when there is the least amount of free money. The mechanism is detailed in the RU-POINT material on customs value.

Routes and payments in 2026

We have offices in Moscow, Vladivostok and Novorossiysk, so we calculate sea and rail delivery times from our ports, not based on the average market range. Here are the routes from China for “white” delivery.

• By sea via Vladivostok and Vostochny. Transit from Shanghai, Ningbo, Qingdao takes 8–14 days, and the port complex has a capacity of about 1 million TEU per year. For goods from southern China, sea transport often competes with rail in terms of both time and cost.
• By rail via Zabaikalsk — Manzhouli. From Xi'an or Zhengzhou to Moscow by express trains in 12–16 days. The Trans-Siberian Railway is operating at capacity, and slots are booked 60–90 days in advance.
• By rail via Mongolia, the Naushki — Sukhbaatar crossing. Longer, but useful when Zabaikalsk is overloaded: from Inner Mongolia to the European part of Russia in 18–22 days.
• By road via Kazakhstan. After autumn 2025, we add an extra 5–10 days to the estimated time for this crossing and warn about it in advance, before signing.

We work through Novorossiysk not only for imports: in past projects, we sent food exports there — 11 containers of chickpeas, 297 tons, with export to Israel.

Payments remain a separate headache. After March 2024, when the impact of secondary sanctions on Chinese banks became fully apparent, direct SWIFT transfers to China became unavailable for most Russian companies. Now regional Chinese banks without SWIFT connectivity, payment agents in Hong Kong, the UAE and Kazakhstan, the CIPS system for some partners, and the SPFS system for settlements within the EAEU are used.

Payment delays through an agent typically take 2–4 weeks, and this must be factored into the supply budget in advance. The supplier will ship the goods after receiving an advance payment, which means with a two-week payment delay and a two-week transit time, you will receive the cargo in a month, not two weeks. This is the planning error we see most often.

Documents we ask clients to provide

The package is divided into two blocks: customs and certification. The customs block, in addition to the contract, invoice and customs declaration, includes a packing list, transport document (bill of lading, CIM or SMGS, CMR for road transport), certificate of origin in Form A for preferences, and an insurance certificate.

For certification under the technical regulations of the EAEU, the following documents are required:

• Declaration or certificate of conformity under the applicable regulation
• Test report from an accredited laboratory
• Power of attorney from the manufacturer if you are the declarant
• Technical documentation and operating manual
• For food products, a phytosanitary or veterinary certificate from the exporting country and registration certificate from Rospotrebnadzor or Rosselkhoznadzor

Separately about the FEAC code. An incorrect code means an incorrect duty rate, and customs interprets this as false declaration regardless of whether the error was intentional or due to ignorance. Therefore, we select the code ourselves based on our product group, rather than copying it from the supplier's invoice.

Most often, the release is delayed by four things: the code on the invoice does not match the code on the declaration, the contract lacks a specification, the actual weight differs from the packing list, and there is no insurance certificate for CIF deliveries. Each of these adds days to the timeline and money to the storage bill.

How to calculate the total cost and choose the right option

Whether to choose “white” or “cargo” depends on your estimate, not your attitude to risk in general. The turning point comes when you calculate the total cost across all lines, not just the freight.

The cost structure for “white” delivery from China on FOB terms is as follows:

• Freight and insurance will cost from $800 to $2,500 for a 20-foot container by sea via Vladivostok, depending on the port of shipment and season
• Brokerage services cost from 15,000 to 40,000 rubles per declaration, depending on complexity
• Customs duty based on the FEAC code
• Import VAT, which under the simplified tax system can be included in expenses or remain in the cost, and under the general system can be deducted if conditions are met
• Certification costs 30,000–200,000 rubles once, for the entire validity period of the certificate, from one to five years
• Storage at the temporary storage facility for delayed release costs about 1,500–3,000 rubles per TEU per day

In our experience, for certain mass categories from China — electronics, clothing, household goods — the total cost of “white” delivery can add 25–40% to the purchase price. For goods with a duty above 15%, such as cars, alcohol and luxury goods, in some calculations the surcharge can reach 60–100%. These are not universal rates: the result depends on the FEAC code, price, route, certification and tax regime. The calculation should be compared not with 2021 cargo rates, but with the current conditions of a specific shipment.

The argument that cargo is cheaper falls apart when you look at the full estimate: the carrier's rate is supplemented by a border intermediary, storage during prolonged control, non-deductible VAT, a lawyer for FTS claims, and the risk of losing the entire shipment. White delivery is more expensive upfront, but in the full estimate it can be more advantageous. We suggest calculating this difference before placing an order with the supplier, not after.

Switching from cargo to white delivery looks like this: first, a preliminary calculation of payments based on your FEAC code — before you place an order, because once the order is placed, there's nothing you can change. Then certification runs in parallel with production, not when the truck is at the border. The official channel allows you to determine payments in advance and build in a time buffer, but the specific impact depends on the product, route and documents.

Want to understand how much your shipment will cost? Send us the FEAC code, supplier's invoice and delivery terms — we'll calculate the payments in advance, before you send the advance payment. The calculation is free: it will show what the final amount consists of and how the white scheme differs from cargo in your case. Customs clearance is one of our main services. We are included in the FTS register of customs representatives and are responsible for the declaration within the limits established by law.