Mandatory marking is being extended on a timetable, and that timetable is known in advance. The problem is not that a requirement appears unexpectedly, but that the code is applied at the plant — sometimes months before the batch reaches your warehouse.
Mandatory marking is a traceability system: every unit of goods receives a unique code, applied to the packaging or to the item itself and registered in a state system. The point of the system is that goods can be traced from production to sale.
For a buyer this means two things. First: some categories that were imported freely yesterday now require marking. Second, and more unpleasant: the code can only be applied where the goods are produced or packaged — that is, at the factory, not in your warehouse.
On the status of the information
Below is the timetable for the introduction of marking according to Forbes Kazakhstan (2026 publication). We give it as a benchmark and recommend checking the current requirements for your product category with the marking operator and with accredited bodies: timetables are adjusted, and the procedure for applying and registering codes depends on the specific product group.
The mechanics are the same for most product groups; the categories and the deadlines differ. The scheme looks like this:
The manufacturer or importer registers in the system
The company putting the goods into circulation gains access to the system and orders codes for the batch. The codes are issued electronically and are tied to a specific product and a specific volume.
The codes are applied to the packaging or the item
This is a production operation. It requires equipment to print or apply codes and a place in the process chain where the operation fits. There is nowhere to fit it in the consignee’s warehouse.
The codes are put into circulation in the system
After application the codes are activated — from that moment the goods are legally in circulation. Before activation the goods physically exist but are not in the system.
The key difference from certification
A declaration of conformity can be issued after the fact — that is work with a document, even if late. Marking cannot be applied after the fact. A code is a physical label on a specific unit of goods. If a batch arrives unmarked, the only options are to open and repack the batch in the importing country, or not to put the goods into circulation at all.
According to Forbes Kazakhstan (2026), the extension of mandatory marking in Kazakhstan follows this timetable:
| Date of entry into force | Product groups |
|---|---|
| 1 February 2026 | Motor oils; part of beer products |
| 1 September 2026 | Beer products in bottles; part of lubricants |
| 1 December 2026 | Light-industry goods: articles of leather and artificial fur; ski suits; part of clothing; bed linen; kitchen textiles |
Note the nature of the groups. This is not industrial raw material or equipment — these are consumer goods bought from China and Southeast Asia in large numbers and small batches. That is precisely why the timetable affects a significant share of importers working with consumer goods.
The logic of “we will sort it out on delivery” does not work here, and it is worth understanding why. Marking is the only admission requirement that is a production operation rather than a document. Three practical conclusions follow from that.
The factory needs to know about the requirement before the batch is started
If you raise marking after the batch has been produced and packed, the factory has two options: unpack and repack finished goods (expensive, and with a risk of damaging the product), or refuse. The second option is more common.
The factory must be able to do it
Not every plant has equipment for printing codes and a place in the line where the operation fits. If it does not, you will need either to change the factory, or to agree an additional operation, or to find a way of applying the codes off the line. All three take time and money, and all three have to be discussed before the order.
Someone has to be the applicant for the codes
The codes are ordered for a specific batch and tied to the company putting the goods into circulation. This is not settled at the moment of shipment but at the stage of agreeing the supply scheme: both the procedure and the allocation of responsibility depend on who is the importer on paper and who orders the codes.
Let us look at what unmarked goods practically mean in a category where marking is mandatory.
| Situation | Consequence |
|---|---|
| The batch has arrived, the codes are not applied | The goods cannot be put into circulation. The options: apply the codes inside the country (repacking by a local contractor), or not put the goods into circulation at all |
| The codes are applied but not entered into the system | Physically the goods are marked, but they are not in the system — circulation remains unlawful until the codes are activated |
| The batch has been put into circulation without marking | Risk of withdrawal from circulation and penalties; for retail chains and marketplaces, grounds to refuse acceptance or delist the product |
| The category entered the timetable after the order was placed | The most common situation: the order is placed, the batch is in production, and the requirement has come into force. The decision is taken on timing — whether or not the batch can be completed before the date |
Four states of a single batch
Note: four different states are possible, and only one of them — “codes applied and put into circulation” — allows the goods to be sold normally. Everything else means extra costs, frozen goods or risk. The difference between the states is created not at the border but at the factory.
The order of operations. All five points are carried out before the order is placed.
Check your category against the timetable
Establish whether your goods fall into the groups where marking already applies or is coming into force. If the supply falls on the boundary date, work out whether the batch can be completed before the requirement takes effect.
Ask the factory whether it can apply codes
This is a question of production capability, not of willingness. The answer “we can do anything” without a description of the technology is not an answer. Ask with what equipment and at what stage of the line the code is applied.
Put the requirement into the contract, not into correspondence
The method of application, the place of application, who supplies the codes and at what stage — these are contract terms. A request in correspondence can go unfulfilled; a contract term cannot.
Establish who orders the codes
Who acts as the applicant and in whose name the codes are issued depends on the supply scheme. This cannot be decided at the moment of shipment — by then the batch has already been produced.
Check the marking during pre-shipment inspection
This is a natural part of pre-shipment control: to see whether the codes are applied, in the right place, on the whole batch. Finding the marking missing at the factory means redoing it; finding it missing in your own warehouse means repacking or not putting the goods into circulation.
Short conclusion
Marking is the only admission requirement that cannot be fulfilled after shipment. A declaration can be issued late, documents can be gathered up afterwards, duty can be paid additionally. A code is not applied to packaging retroactively. So the question “does marking apply to this product” is asked at the stage when the batch has not yet gone into production — together with the question of the HS code and the applicable technical regulations.
Send a description of the item. We will check the category against the timetable, clarify the applicable requirements and tell you exactly what needs to be fixed in the contract with the factory so that the batch arrives ready to be put into circulation.
