Businesses sometimes face a lack of clarity in requirements such as import licensing, customs procedures, labeling, and intellectual property rights enforcement, particularly since Armenia’s accession to the Eurasian Economic Union (EAEU) and the adoption of the EAEU Customs Code. U.S. companies may face a number of tariff and non-tariff trade barriers when exporting to Armenia. Another potential issue is the EAEU’s complex system of standardization, which is based on Russia’s standardization regime. U.S. companies are encouraged to obtain appropriate legal advice or assistance from experienced distributors or consultants on all aspects of EAEU requirements.
Membership in the EAEU is forcing Armenia to apply stricter standardization, sanitary, and phytosanitary requirements in line with EAEU—and, by extension, Russian—standards, regulations, and practices. Armenia has had to surrender control over many aspects of its foreign trade regime in the context of EAEU membership. Tariffs have also increased as part of Armenia’s EAEU accession, granting protection to several domestic industries. Armenia is increasingly beholden to comply with EAEU standards and regulations as post-accession transition periods have, or will soon, end. All Armenian goods circulating in the territory of the EAEU must meet EAEU requirements following the end of relevant transition periods. However, the Armenian government has recommended to importers and exporters that they observe EAEU technical regulations as soon as possible. Companies should consult with the Armenian Conformity Assessment Body for guidance concerning these regulations. Firms can also seek guidance from the Eurasian Economic Commission, the EAEU’s executive body.
Armenia has been a member of the World Trade Organization (WTO) since 2003. It is party to numerous WTO agreements and makes notifications to the WTO under those agreements, but it has not yet accepted protocols to implement some agreements.
The sometimes unpredictable and inconsistent application of customs requirements and procedures represents a barrier to trade. Armenia has made trading easier by introducing self-declaration desks at customs houses and warehouses, investing in new equipment to improve border operations, and introducing risk management systems. However, both local and foreign business representatives indicate that cumbersome and ambiguous laws and procedures as well as their poor and inconsistent administration are major obstacles in dealing with the customs authorities, which has historically resulted in demands for facilitation payments or bribes. Since the new government came to power in May 2018, significant improvements have been reported with respect to corrupt practices, though traders have continued to raise concerns about the professionalism of customs officials and a lack of clarity or predictability in carrying out customs clearance procedures.
Exporters report relatively minor hassles at customs houses relative to importers, but there are some common nuisances. One of these is an informal requirement to submit a special permit issued by the head of the customs house to the customs officer. To obtain such a permit, exporters must petition the head of the appropriate customs house in writing. Although there are no reported cases of rejection, this practice is not in line with the existing legal framework.
Certification of origin is a complicated and costly procedure for exporters. Exporters must present a certificate of origin from the Armenian Chamber of Commerce and Industry (ACCI), after ArmExpertiza, a division of ACCI, has examined the exports. The ACCI applies a complicated and expensive mechanism for issuing certificates; ArmExpertiza must study samples of goods to be exported. Exporters, especially those that export goods in relatively modest quantities, are often confused and discouraged by the procedures and complicated fees. The process was supposedly simplified after the government handed responsibility for these procedures to a quasi-governmental institution designed to help promote exports. In 2002, the government also abolished the state fee for obtaining the certification in an attempt to simplify the procedure and lower the cost to business. However, ArmExpertiza has since raised its fees considerably, justifying the higher cost by arguing that they use more expensive experts.
In case of perceived violations of WTO and other trade agreements, please contact:
International Trade Administration
Enforcement and Compliance
202-482-0063