Since September 1, 2026, two Russian transport documents must generally be electronic, and importers bringing cargo from China often mix them up. A typical question goes like this: "We bring cargo from abroad and pick it up ourselves. The transport company wants the forwarding instruction in electronic form because both sides are Russian residents. Is that done as an ETRN or on paper as before?" The short answer: the ETRN and the EPE are different documents.
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How is the ETRN different from the EPE?
The ETRN (in Russian, "ЭТрН") is the Russian electronic consignment note: a document for a specific carriage of cargo by truck within Russia. The EPE (in Russian, "ЭПЭ") is an electronic forwarding instruction: the client instructs a forwarder to arrange carriage under a freight forwarding contract. The EPE has two mandatory parts (sections each party signs): one from the client and one from the forwarder. Since September 1, 2026, under Russian Federal Law No. 140-FZ, these documents must generally be electronic, with exceptions set by separate orders of the Ministry of Transport. They go to the state information system for electronic transportation documents (GIS EPD). But they are needed at different points of the route.
Which document is needed on each leg of an import from China?
Let us split an import from China into legs. While the cargo travels from China under a single international road consignment note (CMR), there is no domestic Russian ETRN. The international leg is not documented with it. Russian Ministry of Transport Order No. 262 also lists cases where a paper document is allowed. One of them is a foreign company as shipper or consignee that is not in the Russian register of accredited branches and representative offices. So what matters is not the border crossing itself but who the parties are.
The domestic ETRN comes later. It appears when you take the cargo out of the temporary storage warehouse (in Russian, "СВХ", a customs warehouse where cargo stays until customs release) and move it further within Russia between Russian parties. That domestic leg is where the electronic consignment note appears. An instruction to a Russian forwarder, when both sides are Russian residents, is issued as an EPE, even if the cargo itself came from abroad.
What should an importer do?
Three rules follow from this.
- Do not look for a domestic ETRN on the international leg under CMR. It does not exist there, and there is no point asking a foreign shipper for it.
- For the Russian leg from the temporary storage warehouse to your warehouse or to a marketplace, prepare an ETRN, not paper, if both sides are residents and the case is not on the list of exceptions.
- Issue an instruction to a forwarder within Russia as an EPE with two parts. If your counterparty calls it an "ETRN", correct them: it is a different document.
Settle disputed cases (which contract applies, who is a resident, whether the case is an exception) with a lawyer using the text of Law 140-FZ, not with a driver at the warehouse.
Where does air cargo fit in?
Our clients bring cargo from China via Guangzhou (CAN), Shanghai (PVG) and Urumqi (URC). Air carriage goes under an air waybill, which is an international document, and the ETRN does not cover it. Delivery within Russia from the terminal to your warehouse, and our instruction as a forwarder, are issued as electronic documents: an ETRN for the truck and an EPE for the forwarding.
In our experience, the new documents cause almost no questions for those who set up mixed carriage (air plus truck) as one chain, with clear residency on each leg. Confusion starts when the legs are mixed into one document. Keep them separate.
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