Week 1 — Regulatory scoping
Before the sales contract was signed we ran a classification matrix over the SKU list (147 SKUs, three fabric compositions). Every SKU mapped to TN VED chapters 63 (made-up textile articles) or 62 (apparel — for the bathrobes). All products were in scope for TR CU 017/2011 'On the safety of light industry products' — declaration route, not certification. Testing scope: pH, colour fastness, formaldehyde, hygroscopicity, dyestuff migration.
Week 2 — Sampling and lab
12 representative articles were couriered to an accredited testing laboratory in Almaty (registered in the FSA accreditation registry, with a valid ILAC MRA scope for TR CU 017). Turnaround: 9 working days. All samples passed on the first submission; the client's own EU ecolabel testing had already brought them well inside the EAEU thresholds.
Week 3 — Applicant, declaration, marking
- Applicant: the Kazakh importer (contract-based Route C declaration, aligned with the retailer's exclusive purchase order).
- Declaration registered in the FSA Unified Register of Declarations of Conformity, published within 2 working days of filing.
- Marking scheme agreed: EAC mark + care symbols + composition + article code + importer address on the sewn-in label, in Russian.
- Cross-reference matrix produced: GTIP (Turkish export) ↔ TN VED (Kazakh import) ↔ Model code ↔ Declaration number.
Week 4–6 — Routing and clearance
Routing choice: TIR by road via Türkiye → Georgia → Azerbaijan → Caspian ferry Baku → Aktau → road to Almaty. Estimated door-to-door: 14 days. Actual: 15 days (one day held at Aktau for berth availability). Clearance at Almaty inland customs post: green channel, 6 working hours from arrival at the SVH to release.
What we deliberately did not do
- Did not use ATR from Türkiye — ATR is EU-Türkiye customs union, has no legal effect in Kazakhstan. Correct document is a certificate of origin CT-1 or Form A.
- Did not consolidate the four containers under one declaration — separate DT-1 per container, so if one is stopped the retail launch is not blocked.
- Did not accept the manufacturer's OEKO-TEX certificate as a substitute for TR CU 017 testing. It is supporting evidence, never a substitute.
Outcome
First shipment on shelf on the retailer's target date. Two follow-up orders received in the next quarter under the same serial-model declaration (valid 5 years). Client onboarded to our SVH partner in Almaty, moving future orders to a stock-and-release model that halved their working-capital cycle.