Accounting for costs of product certification

Cost structure for certification

There are indirect and direct costs of certification. Indirect ones involve spending on quality assurance. This:

Elimination of detected defects.
Quality control.
Measures to prevent defects.

There are also direct costs for certification. They are specified in paragraph 4.2 of the Certification Rules, approved by Resolution No. 44. Costs include the following:

Work carried out by an accredited center.
Samples needed for testing.
Expenses for the tests themselves, which are carried out in the laboratory.
Checking the state of production and its certification.
Checks performed during control.
Review of the application.
Costs for storing and packaging samples that will be sent to the laboratory.

All expenses considered can be reflected in the costs of certification.

AUTHOR'S ADVICE

You need to understand that as soon as technical regulations are adopted for a particular product, it is excluded from the corresponding unified list. But what has been said, of course, does not mean that after this it does not need to be declared; it’s just that the requirements for this product and the forms for its declaration are already provided for by the technical regulations. Currently, due to the adoption of the relevant technical regulations, almost all sections of food products are excluded from the unified list of products subject to declaration of conformity, with the exception of products from the fishing industry, feed production products and microbiological industry products.

Accounting for the purposes of applying the simplified tax system

According to paragraphs. 4, 5, 7 PBU 10/99 expenses are recognized in accounting depending on their nature, conditions of conduct and areas of activity of the organization as part of expenses for ordinary activities or as part of other expenses. Those costs that are associated with the manufacture and sale of products are recognized as expenses for ordinary activities, and those that are not associated are recognized as other expenses.

Accounting will depend on:

does the company engage a special certification company, an attorney, or a certification specialist;
or independently carries out certification.

Example 1.

Kalinka LLC carries out certification of personal protective equipment (armored clothing). For this purpose, the company entered into an agreement with Certification LLC for certification.

The following entries will be made in accounting:

Debit	Credit	Sum	Description
76	51	20 000	Advance transferred to intermediary
20	76	40 000	Based on the report and certificate, the costs of certification are recognized in full
76	51	20 000	The final payment has been made in connection with the certification

However, certification and declaration can be carried out independently. In this case, state duties will be reflected in the accounting.

Example 2.

Meteor LLC plans to declare pesticides. To do this, you need to pay a state fee. According to the Tax Code of the Russian Federation, a fee of 5,000 rubles is established for state registration of pesticides and agrochemicals, potentially hazardous chemical and biological substances.

In accounting, the duty will be reflected as follows:

Debit	Credit	Sum	Description
68	51	5000	State duty paid
44	68	5000	State duty is included in the cost of pesticides

However, it is worth noting that self-registration and obtaining certificates and declarations significantly reduces costs, because tests and measurements are required.

Let's imagine a third situation.

Example 3.

purchases products abroad and receives a certificate for a specific batch of products. Certification costs are included in the period in which they are incurred. Costs include tests, measurements, etc., and in the future the products will be used for resale.

In accounting, the duty will be reflected as follows:

Debit	Credit	Sum	Description
44	60	50 000	The costs of product certification are reflected
90	44	50 000	Costs for product certification are written off as expenses for ordinary activities

Let's imagine a situation in which a company is a manufacturer and produces some kind of product that is subject to certification, which involves long-term use. In this case, the issue of cost accounting will arise.

The costs of obtaining a certificate are included in monthly expenses (clauses 25, 26 of PBU 14/2007, clause 9 of PBU 10/99):

if the certificate is issued for a certain period - during this period;
if the certificate is unlimited - for a period determined by the organization itself (more than a year).

GOOD TO KNOW
In contrast to catering products sold outside catering establishments and subject to declaration of conformity, assessment (confirmation of conformity) of food products of catering establishments intended for sale during the provision of services, as well as the processes of its sale, is carried out in the form of state supervision (control) over compliance with the requirements of the technical regulations of the Customs Union TR CU 021/2011 “On the safety of food products” and (or) technical regulations of the Customs Union for certain types of food products (clauses 1, 3, Article 21 TR CU 021/2011).

Tax accounting for the purposes of applying the simplified tax system

Taxpayers applying the simplified tax system with the object “income minus expenses” have the right to recognize expenses for certification of services on the basis of paragraphs. 26 clause 1 art. 346.16 of the Tax Code of the Russian Federation after actual payment and signing of the certificate of completion of work with the certification body (clause 2 of Article 346.17 of the Tax Code of the Russian Federation).

Voluntary confirmation of conformity is carried out in the form of voluntary certification. Mandatory confirmation of conformity is carried out in the forms of acceptance of a declaration of conformity and mandatory certification. There are a number of explanations from officials that also confirm the possibility of accounting for costs of certification and declaration (letter of the Ministry of Finance of Russia dated March 18, 2013 No. 03-03-06/1/8186).

GOOD TO KNOW
When determining the tax base for the tax paid in connection with the application of the simplified system, the taxpayer has the right to reduce the income received by him for expenses associated with obtaining a sanitary and epidemiological report and conducting an instrumental examination.

Judges also consider such expenses to be legitimate in the event of claims from the tax authority. In particular, in the resolution of the Federal Antimonopoly Service of the Moscow District dated 04/02/2010 No. KA-A40/2846-10, the court recognized the costs of certification as justified, since the taxpayer aims to increase the income received by the organization from its activities during the validity period of the issued certificates.

Thus, there are no risks regarding the recognition of expenses when applying the simplified taxation system.

Tax accounting

Certification costs require payment of VAT and income tax.

Features of VAT calculation

The company has the right to reduce the total amount of VAT by the amount of tax that was presented to the company when purchasing goods or services for the execution of transactions considered subject to taxation. The deduction is carried out on the basis of invoices issued by product sellers. An invoice can only be issued after the goods have been accounted for. A deduction can be made in respect of VAT amounts accrued on certification expenses if these conditions are simultaneously met:

The corresponding services were recorded in accounting under DT account 97.
Accounting entries were made based on existing primary documents.
There is an invoice that is issued in accordance with the law.
Certification is needed for activities that will be subject to VAT.

The transfer of product samples to the laboratory for testing will not be subject to VAT. This is due to the fact that this procedure does not involve the sale of products. The company is not deprived of ownership of the designs. The subject of taxation is the transfer of products for the needs of the company, if expenses on the goods are not deductible when determining income tax. In this situation, you need to take into account expenses when assessing taxes.

If a company stops producing products before the expiration of the document of compliance, the VAT deduction will not be restored. This is due to the fact that termination of issue with a valid certificate is not included in the list of situations in which VAT can be restored (clause 3 of Article 170 of the Tax Code of the Russian Federation).

Income tax

Certification costs must be taken into account in the structure of other costs arising during production and sales. In this case, the type of certification being carried out is not important: voluntary or compulsory. Related expenses reduce taxable profit only when the requirements of paragraph 1 of Article 252 of the Tax Code of the Russian Federation are met.

For the purpose of taxation of profits, expenses for a voluntary procedure are taken into account only when the event is carried out in the form of quality assurance on the basis of the law on technical regulation.

Voluntary certification cannot duplicate a mandatory event. The exception is inspections during which there is an analysis of various parties.

A company can include expenses for samples provided to the laboratory as expenses that reduce taxable income. They are needed for testing to determine compliance with the requirements. Sample costs include the cost of the sample itself, as well as the costs of storing and packaging it.

The possibility of reducing taxable income is due to the fact that samples are likely to be damaged during testing. That is, it will not be possible to implement them in the future. The corresponding conclusion was made by the FAS in a resolution dated January 23, 2007. If the samples were damaged, it is necessary to draw up an act for their write-off. The corresponding position is given in the letter of the Department of Tax Administration dated April 23, 2001.

IMPORTANT! When carrying out certification, even if it is mandatory, you need to pay a fee. It cannot be included in expenses. The amount of the duty reduces the profit subject to tax.

Taxation will be determined by what methods the company uses:

If a company uses the cash method, certification costs are recognized only after they are actually incurred. For example, research costs are recognized only after actual payment for laboratory services has occurred.
If a company uses the accrual method, expenses are recognized as taxable in the period in which they are incurred. It does not matter when exactly the payment occurred.

The letter of the Ministry of Finance No. 03-03-02/268 states that expenses must be distributed throughout the validity period of the certificate. If the company ceases issuing the document before the document expires, the balance of expenses that have not been transferred is recognized for tax purposes as a lump sum. However, gradual acceptance of spending is only one position. There is another one, according to which losses can be recognized at a time. In this case, there is no distribution among reporting periods. This position is confirmed by paragraphs. 2, paragraph 7 of Article 272 of the Tax Code of the Russian Federation.

When to include certification of your own products as expenses in tax and accounting?

R.G. Berezhnov, author of the answer, Ascon consultant for accounting and taxation

QUESTION

The organization carries out certification of the quality of the products we manufacture. The certificate will be valid for a long period with the counterparty for products that we will produce more than once. We carry out certification voluntarily.

We signed the certification agreement in a step-by-step manner: after completing the stage, it is closed with documents.

How to accept expenses in used and used?

ANSWER

In the situation under consideration, the costs of product certification can be taken into account at a time, after all certification work has been completed and a positive result has been obtained. In order to bring tax and accounting accounting closer together, this method of accounting can be applied both in tax and accounting.

JUSTIFICATION

Costs for certification of products (works, services) should be taken into account as part of other expenses associated with production and sales (excluding VAT, subject to deduction) (clause 2, clause 1, article 264, clause 1, article 170 of the Tax Code of the Russian Federation). Recognize expenses as of the date of drawing up a document confirming the provision of certification services (for example, an acceptance certificate for work performed) (clause 3, clause 7, article 272 of the Tax Code of the Russian Federation, Letter of the Ministry of Finance of Russia dated July 29, 2019 N 03-03-06/1 /56593, dated 06/08/2017 N 03-03-06/1/35781, Federal Tax Service of Russia dated 03/25/2019 N SD-4-3/5272).

In accounting, certification costs can be recognized in one of three ways, as specified in the accounting policy:

recognized as expenses for ordinary activities at a time on the date of execution of the document confirming the provision of certification services (clause 5, PBU 10/99 “Expenses of the organization”);
preliminarily taken into account in deferred expenses (FPR) and recognized as expenses for ordinary activities during the validity period of the certificate in the manner established by the organization (for example, evenly) (clause 65 of Regulation No. 34n, Letter of the Ministry of Finance of Russia dated January 12, 2012 No. 07 -02-06/5, clause 5, 19 PBU 10/99);
take into account the certificate as an intangible asset and include the costs of obtaining it as part of expenses for ordinary activities through depreciation (clause 11 of Interpretation R113 “Exclusive rights as a criterion for the recognition of intangible assets”, adopted by the BMC Committee on Interpretations on 09.09.2011, approved in the final version 12/26/2011, clause 23 PBU 14/2007 “Accounting for intangible assets”, clause 5, PBU 10/99). This accounting option is only possible if the certificate of conformity meets the conditions provided for in clause 3 of PBU 14/2007.

In order to bring accounting closer to tax accounting, we recommend recognizing the costs of certification of products (works, services) at a time. In addition, this method is more consistent with the requirements of prudence and rationality that accounting policies should ensure.

In tax accounting, if errors are detected in the calculation of the tax base, which resulted in excessive payment of tax, you can recalculate it, as well as the amount of tax (paragraph 2, 3, clause 1, article 54 of the Tax Code of the Russian Federation):

for the tax (reporting) period in which the error was made;

for the tax (reporting) period in which it was identified.

The Ministry of Finance of Russia confirms that the taxpayer has the right to recalculate the tax base and the tax amount for the tax (reporting) period in which errors (distortions) were identified that caused the overpayment (Letters dated 04.08.2017 N 03-03-06/2/50113, dated 01.09.2014 N 03-11-06/1/43546).

Costs for certification in accounting

Paragraph 4 of PBU 10/99 states that expenses in accounting are recognized either in the structure of expenses for the main forms of activity, or in the structure of other expenses. Expenses for the main form of activity include expenses associated with production and sales. Expenses for certification are included in this composition, since they are needed to establish compliance of the manufactured product with the requirements.

Expenses must be taken into account in the period in which they appeared. It does not matter when the actual payment occurred. Expenses that arose in the current reporting period, but are attributable to subsequent periods, are recorded in the structure of expenses of subsequent periods. They need to be written off. The write-off procedure is determined by the company itself.

Accounting entries

To record expenses for certification, these accounting entries are used:

DT60 KT51. Payment for certification services based on an extract from a banking institution.
DT97 KT43. Write-off of the cost of samples sent for research.
DT97 KT60. Fixation in the expenses of subsequent periods of the cost of work for certification on the basis of an agreement with the center, an act of execution of work.
DT19 KT60. Reflection of VAT on services.
DT68 KT19. Purpose for VAT deduction.

Every month you need to record this wiring: DT20 KT97. Reflection of costs for certification in the cost structure of products.

If the company's accounting policy involves one-time reflection of expenses in tax accounting, this entry is used:

DT68 KT77. Deferred tax liability.
DT77 KT68. Repayment of obligation.

The last entry will be used every month for the duration of the certificate - 3 years. If there are no primary documents confirming expenses, then postings cannot be made.

GLAVBUKH-INFO

The basic concepts and rules for certification and declaration of conformity are established by Federal Law of December 27, 2002 No. 184-FZ “On Technical Regulation”.

This Federal Law regulates legal relations with the following objects of technical regulation:

products;
processes of production, operation, storage, transportation, sales and disposal;
works, services.

The requirements for regulated objects are divided into mandatory requirements and requirements applied on a voluntary basis.

Mandatory requirements apply to products and processes associated with their life cycle from production to disposal.

Voluntary requirements apply to products, processes of work and provision of services.

Requirements for regulated objects are established by technical regulations, provisions of standards, codes of practice or terms of contracts.

A technical regulation is a document adopted by an international treaty of the Russian Federation, ratified in the prescribed manner, and establishing mandatory requirements for the application and implementation of technical regulation objects.

A standard is a document that establishes product characteristics, implementation rules and characteristics of the design processes (including surveys), production, construction, installation, commissioning, operation, storage, transportation, sales and disposal, performance of work or provision of services.

A set of rules is a document in the field of standardization that contains technical rules and/or descriptions of the processes of production, construction, installation, commissioning, operation, storage, transportation, sale and disposal of products and is applied on a voluntary basis.

Documentary certification of the compliance of products or other objects, production processes, construction, installation, adjustment, operation, storage, transportation, sales and disposal, performance of work or provision of services with the requirements of technical regulations, provisions of standards, codes of practice or terms of contracts is called confirmation of conformity.

Confirmation of compliance on the territory of the Russian Federation can be voluntary or mandatory.

Mandatory confirmation of compliance is carried out in the following forms:

mandatory certification;
acceptance of the declaration of conformity.

Only products put into circulation on the territory of the Russian Federation can be the object of mandatory confirmation of conformity. The list of objects subject to mandatory certification is established by a decree of the Government of the Russian Federation.

Mandatory certification is carried out by the certification body on the basis of an agreement between the applicant and the certification body.

An applicant is an individual or legal entity who, to confirm compliance, accepts a declaration of conformity or applies for a certificate of conformity and receives a certificate of conformity.

Work on mandatory confirmation of compliance is subject to payment on the basis of an agreement with the applicant. The cost of work on mandatory confirmation of product conformity is determined regardless of the country and/or place of origin of the product, as well as the persons who are the applicants.

Certification is a form of confirmation by a certification body of compliance of objects with the requirements of technical regulations, provisions of standards, codes of practice or terms of contracts.

Product compliance with all established requirements is confirmed by a certificate of conformity issued by the certification body.

A certificate of conformity is a document certifying the compliance of an object with the requirements of technical regulations, provisions of standards, codes of practice or terms of contracts.

The validity period of the certificate of conformity is determined by the relevant technical regulations.

The form of the certificate of conformity is approved by the federal executive body for technical regulation.

Declaration of conformity is a form of confirmation of product compliance with the requirements of technical regulations.

Declaration of conformity is carried out according to one of the following schemes:

adoption of a declaration of conformity based on own evidence;
acceptance of a declaration of conformity based on one’s own evidence, evidence obtained with the participation of a certification body and/or an accredited testing laboratory (hereinafter referred to as a third party).

A scheme for declaring conformity with the participation of a third party is established in the technical regulations in the event that the absence of a third party leads to failure to achieve the goals of conformity assessment.

Declaration of conformity is a document certifying the compliance of products released into circulation with the requirements of technical regulations.

The declaration of conformity completed by the applicant is subject to registration in the unified register of declarations of conformity within three days.

The validity period of the declaration of conformity is determined by the technical regulations.

The form of the declaration of conformity is approved by the federal executive body for technical regulation.

The Declaration of Conformity and the Certificate of Conformity have equal legal force regardless of the mandatory confirmation of conformity schemes and are valid throughout the Russian Federation.

Voluntary confirmation of conformity is carried out in the form of voluntary certification. Voluntary confirmation of conformity can be carried out to establish compliance with national standards, organizational standards, codes of practice, voluntary certification systems, and contract terms.

The objects of voluntary confirmation of conformity are products, processes of production, operation, storage, transportation, sale and disposal, work and services, as well as other objects for which standards, voluntary certification systems and contracts establish requirements.

Voluntary confirmation of conformity is carried out at the initiative of the applicant under the terms of an agreement between the applicant and the certification body.

A voluntary certification system can be created by a legal entity and/or individual entrepreneur or several legal entities and/or individual entrepreneurs.

The voluntary certification system can be registered by the federal executive body for technical regulation. The fee for registering a voluntary certification system is subject to credit to the federal budget.

For accounting purposes, expenses for mandatory product certification, as well as for declaration of conformity with the participation of a third party, are considered expenses for ordinary activities and are recognized in the reporting period in which they occurred, regardless of the time of actual payment.

As a rule, certificates of conformity and declarations of conformity are issued for a certain period (six months, a year, two years, etc.) and therefore the costs of product certification should first be reflected as part of deferred expenses.

Taking into account the above, expenses for mandatory certification of products are reflected in accounting as the debit of account 97 “Deferred expenses” in correspondence with account 76 “Settlements with various debtors and creditors”.

The cost of a unit of finished products transferred to the certification body for testing is reflected in account 97 “Future expenses” in correspondence with account 43 “Finished products”.

Subsequently, the certification costs recorded on account 97 during the period to which they relate are written off in equal monthly installments to production costs in the manner established by the organization in its accounting policies (evenly, in proportion to the volume of production, etc.).

Write-off costs for product certification are included monthly in the cost of production and are reflected in accounting as the debit of account 26 “General business expenses” in correspondence with the credit of account 97 “Deferred expenses”.

These expenses participate in the formation of the organization’s financial result for the reporting period. When generating the financial result for the reporting period, these expenses, together with other expenses, are written off to the debit of account 90 “Sales” (subaccount 90–2 “Cost of sales”).

Documents confirming the costs of certification are contracts with certification bodies, invoices, bank statements and payment orders.

Expenses associated with voluntary certification of products are not included in expenses for ordinary activities. These expenses are recognized as other expenses and are reflected in accounting as the debit of account 91 “Other income and expenses” in correspondence with account 76 “Settlements with various debtors and creditors”.

Tax aspects. The amount of VAT presented by suppliers of product certification work is reflected in the debit of account 19 “Value added tax on acquired assets” and credit 76 “Settlements with various debtors and creditors”.

The specified amount of VAT can be claimed in full for tax deduction on the basis of invoices issued by certification bodies after the certification work has been accepted for accounting.

VAT for tax accounting purposes, expenses for mandatory certification of one’s own products, as well as for declaration of conformity with the participation of a third party, are classified as other expenses associated with the production and sale of products, and are included in the expenses of the current period during the period for which the certificate of conformity is issued or declaration of conformity.

In accounting, payment of costs for mandatory certification and their write-off can be reflected in the following entries:

No.

Contents of business transactions	Corresponding accounts
Contents of business transactions	Debit	Credit
1	Reflects payment for work on mandatory certification of own products (including VAT)	76	51
2	Expenses for mandatory certification of own products (excluding VAT) are reflected in deferred expenses	97	76
3	The amount of VAT presented by suppliers of work on mandatory certification of their own products is reflected	19	76
4	The cost of a unit of product transferred to the certification body for testing has been written off	97	43
5	The amount of VAT paid on work performed for mandatory product certification was submitted for deduction.	68-1	19
6	Part of the costs of mandatory certification attributable to the past reporting month was written off as production costs.	26	97
7	Certification expenses are written off to cost of sales (these expenses are written off at the end of the reporting month as part of similar expenses)	90-2	26

When purchasing imported products that are subject to mandatory confirmation of conformity, a declaration of conformity or a certificate of conformity must be submitted to the customs authorities simultaneously with the customs declaration by the applicant or a person authorized by the applicant.

In the absence of a foreign certificate or the presence of a foreign certificate that is not recognized in the Russian Federation, it is necessary to obtain a Russian certificate of conformity or a declaration of conformity. Submission of these documents is not required if products are placed under the customs regime of refusal in favor of the state.

The conditions for the import into the territory of the Russian Federation of products subject to mandatory confirmation of conformity are established by Art. 29 of the Federal Law of December 27, 2002 No. 184-FZ.

Expenses for mandatory confirmation of conformity of imported products are reflected in accounting in the same manner as for products manufactured in the Russian Federation.

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How to reflect product certification in accounting

Certifying the quality of a product or product is a costly matter. It is necessary to conduct tests, ensure transportation of certified samples to the testing site and back, prepare documents for certification, and the like. Sometimes the cost amounts can be large, sometimes not. In which accounts should these costs be recorded and how should they be classified: as assets or as operating expenses? And if assets, what exactly? It all depends on the situation as well as the professional judgment of the individual accountant. So there is no single solution.

Content

Inexpensive certificates

Each organization decides for itself whether the costs of certification are significant for it or not from the point of view of its impact on financial results. As a reasonable criterion, you can use, for example, an indicator such as the share of certification costs in the cost of goods or products.

The materiality criterion must be enshrined in the accounting policy so that it is clear to inspectors, owners, and everyone else who will get acquainted with your statements why you take into account “certification” expenses one way and not another.

Minor amounts spent on any certification can be immediately written off to current sales expenses, guided by the principle of rationality.

Note. By the way, in tax accounting, many organizations also immediately write off the cost of inexpensive certificates as other expenses. Moreover, despite the fact that the Ministry of Finance often recommends extending it for the duration of the certificate.

Certification costs are significant for you

SITUATION 1. We certify a batch of goods

Obviously, the cost of obtaining a certificate should be included in the cost of your inventory. So if you have not yet accounted for the cost of the certified batch of goods (or your own products), then write off the costs of certification to account 41 “Goods” (or to account 20 “Main production”).

If the cost of goods (products) in your accounting has already been determined, certification costs can be taken into account as distribution costs, reflecting them on account 44 “Distribution costs”.

FROM AUTHENTIC SOURCES

SUKHAREV IGOR ROBERTOVICH — Head of the Department of Accounting and Reporting Methodology of the Department for Regulation of State Financial Control, Auditing, Accounting and Reporting of the Ministry of Finance of Russia

“If the subject of certification is specific units or batches of goods, then the costs of such certification should increase the cost of the certified goods.”

But there is another opinion.

FROM AUTHENTIC SOURCES

EFREMOVA ANNA ALEKSEEVNA - General Director of the Audit Office

“If inventories are purchased for resale, then certification costs must be reflected in account 44. However, as a rule, often, according to the conditions established in the accounting policy, this account is reset to zero at the end of the month (all costs collected on it are transferred to the financial performance accounts) . It turns out that expenses recognized at the time of provision of services for obtaining a certificate will be charged to the financial result in the same period, although the goods themselves will not yet be sold. This will create an imbalance between the timing of recognition of revenue and expenses associated with the sale. That is, the financial result will be distorted both in the period of incurring costs (profit is underestimated) and in the period of selling goods (profit is overstated). In this case, for a reasonable distribution of costs between reporting periods, since the certificate was issued for a specific batch of goods, its cost must be taken into account as deferred expenses (FPR) and written off in proportion to the volume of sales of this batch.”

So, another option is to reflect the costs associated with the certification of a batch of goods or products as deferred expenses, writing them off gradually. But when preparing financial statements, it is no longer recommended to reflect all financial statements on one line. It is better to name your assets (if they are significant) so that all users of the statements understand what is hidden under this or that figure.

SITUATION 2. We certify a certain type of product or product

If you are certifying something that you are going to produce (or sell) over a long period, and cannot relate such certification to a specific batch of goods or products, then “certification” costs must definitely be taken into account separately.

When the period for which you need the certificate falls within the current year, you can write off the costs for it at a time. This will not in any way affect the accuracy of the financial result calculated at the end of the year. But if the certificate you received is needed for a longer period of time, you will have to decide in which account to record the costs for it and how to name them.

OPTION 1. Certificates are deferred expenses.

You can take into account the costs of the certificate in account 97 “Deferred expenses”. And in the reporting they will be reflected like this.

FROM AUTHENTIC SOURCES

EFREMOVA ANNA ALEKSEEVNA, Development Vector LLC

“STEP 1. Determine the period for writing off RBP as part of sales expenses. If the certificate is issued for a certain period, its value is written off using the straight-line method. If the period is unknown, the organization must itself (using an expert method) determine the period during which this type of goods (products) will be sold, and during this period write off costs using the straight-line method. STEP 2. We determine which line of the balance sheet will reflect the remaining costs for certification of goods. RBP are indicated as a decoding of one of the types of inventories in the “Inventories” line (similar to work in progress). If the cost of this asset is significant, it should be allocated to a separate line “Certification costs”, located outside the line “Inventories”. We must not forget about the need to divide between long-term assets and short-term ones. To do this, in the balance sheet the indicator “BPR” is divided into two decoding entries, as is done, for example, for accounts receivable.”

OPTION 2. Certificates are intangible assets.

You can also use account 04 “Intangible assets”.

FROM AUTHENTIC SOURCES

SUKHAREV IGOR ROBERTOVICH, Ministry of Finance of Russia

“Certification costs generally correspond to the characteristics of the asset. Thanks to them, the organization will receive benefits in the future in the form of revenue from the sale of goods. If the subject of certification is a type of product and the certificate cannot be correlated with specific lots or units, then such a certificate should generally be recognized as an intangible asset according to PBU 14/2007 “Accounting for Intangible Assets”.

The fact that you do not have exclusive rights to something in this case does not prevent you from doing it. After all, the exclusive right as a criterion for recognizing intangible assets was enshrined in PBU 14/2000, which was applied until 2008. But in the current PBU 14/2007 there is no such condition.

If you take into account the cost of certification as an intangible asset, it will be depreciated over its useful life. To determine it, you need to evaluate your plans for using the certificate. Moreover, even if you make a mistake, you can subsequently revise the period of its use. After all, this period is just an estimate that can be clarified. So, when registering the costs of certification as an intangible asset, we strongly recommend that you establish the SPI - at least based on indicative data. Because otherwise, if you find that your intangible asset does not have any specific useful life, you will not be able to charge depreciation in your books.

CONCLUSION

Regardless of which account you record a certificate for a certain type of product or product on - account 04 or account 97, the principle of writing off its value will be the same. The costs for the certificate will not be written off at once, but gradually. This will not affect the financial result.

If you recognize your certificate as an intangible asset, it will be easier for you to fill out reports. Although, of course, most accountants are more accustomed to accounting for certification costs as deferred expenses.

Note. In tax accounting, it is impossible to take into account the costs of certification as an intangible asset. However, for profit tax purposes, the Ministry of Finance recommends that certification costs be written off gradually over the validity period for which the certificate was issued. So the amounts that will be taken into account as part of the expenses of the current period will be the same. This means that there will be no need to reflect differences according to PBU 18/02.

***

If you have serious doubts about how to account for certain costs: as an asset or as an operating expense, it is better to include everything as an expense, based on the accounting principle of prudence. This fully applies to certification costs.

First published in the magazine "Glavnaya Kniga" 2012, N 7

Elina L.A.

Find out more about the journal "General Ledger"

Legal documents

Article 264 of the Tax Code of the Russian Federation. Other costs associated with production and (or) sales

PBU 14/2007

PBU 18/02

Accounting for intangible assets

estimated value that can be clarified

Accounting for certification costs

Leonid Ioffe, auditor

Certification is a form of confirmation of the compliance of goods, products, works, services with the requirements of technical regulations, provisions of standards or terms of contracts (Article 2 of the Federal Law of December 27, 2002 No. 184-FZ “On Technical Regulation”). Confirmation of such compliance on the territory of the Russian Federation can be either voluntary or mandatory.

Mandatory confirmation of conformity
Mandatory confirmation of conformity is carried out only in cases established by the relevant technical regulations, and solely for compliance with the requirements of the technical regulations. The object of mandatory confirmation of conformity can only be products released into circulation on the territory of the Russian Federation (Article 23 of Law No. 184-FZ).

Mandatory confirmation of conformity is carried out in the forms of acceptance of a declaration of conformity and mandatory certification.

Declaration of conformity can be carried out by:

accepting a declaration of conformity based on your own evidence;
accepting a declaration of conformity on the basis of one’s own evidence, evidence obtained with the participation of a certification body and (or) an accredited testing laboratory (center) (Article 24 of Law No. 184-FZ).

When declaring conformity on the basis of its own evidence, the applicant independently generates evidentiary materials in order to confirm product compliance with the requirements of technical regulations.
Technical documentation, results of own research (tests) and measurements and (or) other documents that served as a reasoned basis for confirming product compliance with the requirements of technical regulations are used as evidentiary materials. The composition of evidentiary materials is determined by the relevant technical regulations. When declaring compliance on the basis of its own evidence and evidence obtained with the participation of a third party, the applicant, at his choice, in addition to his own evidence formed in the above order:

includes in evidentiary materials protocols of studies (tests) and measurements carried out in an accredited testing laboratory (center);
provides a quality system certificate (which provides for control (supervision) of the certification body that issued it) over the object of certification.

A quality system certificate can be used as part of evidence when accepting a declaration of conformity for any product, except if for such products the technical regulations provide for another form of confirmation of conformity.
The declaration of conformity contains:

name and location of the applicant;
name and location of the manufacturer;
information about the object of conformity assessment, allowing to identify this object;
name of the technical regulation for compliance with the requirements of which the product is confirmed;
indication of the conformity declaration scheme;
the applicant’s statement about the safety of the product when used in accordance with its intended purpose and the applicant’s taking measures to ensure product compliance with the requirements of technical regulations;
information about the studies (tests) and measurements carried out, the quality system certificate, as well as the documents that served as the basis for confirming product compliance with the requirements of technical regulations;
validity period of the declaration of conformity;
other information provided for by the relevant technical regulations.

A declaration of conformity drawn up in accordance with the established rules is subject to registration by the federal executive body for technical regulation within three days.
Mandatory certification is carried out by a certification body accredited in the manner established by the Government of the Russian Federation, on the basis of an agreement with the applicant. Certification schemes used to certify certain types of products are established by the relevant technical regulations. Product compliance with the requirements of technical regulations is confirmed by a certificate of conformity issued to the applicant by the certification body.

In addition to the stated items of the declaration of conformity, the certificate of conformity also contains the name and location of the certification body that issued it.

The Declaration of Conformity and the Certificate of Conformity have equal legal force regardless of the schemes for mandatory confirmation of conformity and are valid throughout the Russian Federation (clause 3 of Article 23 of Law No. 184-FZ). Their validity period is determined by the relevant technical regulations.

Research (testing) and measurements of products during mandatory certification are carried out by accredited testing laboratories (centers).

The list of goods subject to mandatory certification was approved by Decree of the Government of the Russian Federation dated August 13, 1997 No. 1013 (as amended on December 17, 2005 No. 775). Until February 2004, certain types of work and services were also subject to mandatory certification. Their list was given in the same resolution No. 1013. These included: maintenance and repair of vehicles, retail trade and catering services. However, by Government Decree No. 72 dated February 10, 2004, this list was declared invalid.

When importing into the territory of the Russian Federation products that are subject to mandatory confirmation of conformity, a declaration of conformity or a certificate of conformity or documents on their recognition are submitted to the customs authorities simultaneously with the customs declaration.

Documents confirming conformity, marks of conformity, research (test) and product measurement protocols received outside the Russian Federation can be recognized on the territory of Russia in accordance with international treaties of the Russian Federation (Article 30 of Law 184-FZ).

For the purposes of customs clearance of products, lists of products and foreign economic activities are approved by the Government of the Russian Federation on the basis of technical regulations. Letter No. 01-06/107 of the Federal Customs Service of Russia dated January 12, 2005 (as amended on December 29, 2005) provided a list of goods that require confirmation of mandatory certification upon release into the customs territory of the Russian Federation.

Voluntary confirmation of compliance

Voluntary confirmation of conformity is carried out to establish compliance with national standards, organizational standards, voluntary certification systems, and contract terms. The object of voluntary confirmation of conformity is products, processes of production, operation, storage, transportation, disposal, work and services, as well as other objects for which standards, voluntary certification systems and contracts establish requirements.

Voluntary confirmation of conformity is carried out in the form of voluntary certification at the initiative of the applicant under the terms of an agreement between him and the certification body (Article 21 of Law No. 184-FZ). At the same time, the certification body confirms the conformity of objects of voluntary confirmation of conformity and issues certificates of conformity for objects that have passed it.

Objects certified in the voluntary certification system may be marked with the sign of conformity of the voluntary certification system. The procedure for applying such a mark of conformity is established by the rules of the relevant voluntary certification system.

The application of the mark of conformity to the national standard is carried out by the applicant on a voluntary basis in any way convenient for the applicant in the manner established by the national standardization body.

A number of decrees of the State Standard of Russia have approved regulatory documents regarding certification:

Rules for certification in the Russian Federation - decree dated 10.05. 2000 No. 26;
The procedure for product certification in the Russian Federation is by Decree No. 15 dated September 21, 1994;
Rules for certification “Payment for work on mandatory certification of products and services” - Resolution No. 44 dated August 23, 1999.

Cost accounting

In accounting, expenses for certification of own products, carried out both mandatory and voluntary, are fully included in expenses for ordinary activities (clause 5 of PBU 10/99 “Organization expenses”; approved by order of the Ministry of Finance of Russia dated 06.05 .99 No. 33n).

These expenses consist of the cost of the contract for certification concluded with a special body for its implementation, as well as the cost of product samples that are submitted for testing and are not subject to further sale. If the declaration of conformity is accepted on the basis of one’s own evidence, then one’s own costs and not its implementation are taken as certification costs.

As mentioned above, a certificate of conformity for products is issued for a certain period. Costs incurred by the organization in the reporting period, but relating to subsequent reporting periods, are reflected in the balance sheet as a separate item as deferred expenses. These costs are subject to write-off in the manner established by the organization during the period to which they relate (clause 65 of the Regulations on accounting and financial reporting in the Russian Federation; approved by order of the Ministry of Finance of Russia dated July 29, 1998 No. 34n).

Instructions for the use of the Chart of Accounts for accounting financial and economic activities of organizations (approved by order of the Ministry of Finance of Russia dated October 31, 2000 No. 94n) to summarize information on expenses incurred in a given reporting period, but relating to future reporting periods, provide for the use of account 97 “Expenses future periods." Therefore, the costs of certification should first be reflected in the above-mentioned account. During the validity period of the certificate, they will be written off monthly as expenses for ordinary activities in accordance with the established procedure for their write-off: evenly, in proportion to the volume of production, etc. The following entries are made in accounting:

Debit 97 Credit 60

— the costs of obtaining a certificate of conformity are taken into account;

Debit 19 Credit 60

— VAT paid to the organization that carried out the certification was allocated;

Debit 97 Credit 43

— the cost of finished product samples submitted for certification was written off;

Debit 20 Credit 97

— expenses for certification in the part attributable to the current month are included in production costs.

Example 1 An organization is engaged in the production of household radio-electronic equipment.
On May 11, 2006, she transferred 7,670 rubles, including VAT - 1,170 rubles, under an agreement with the body conducting product certification. At the same time, it handed over 2 samples of finished products for certification tests. Their cost amounted to 13,660 rubles. On June 1, a certificate of conformity was received for the period until May 30, 2008. In accounting, the operation to obtain a certificate is accompanied by the following entries. In May:
Debit 60 subaccount “Settlements on advances issued” Credit 51
— 7670 rub. — prepayment for certification is transferred;
Debit 43 subaccount “Transferred samples” Credit 43
— 13,660 rub. – samples were submitted for certification.
In June:
Debit 97 Credit 60
— 6500 rub. (7670 - 1170) - reflects the cost of the received certificate of conformity;
Debit 19 Credit 60
— 1170 rub. – VAT is allocated on certification costs;
Debit 97 Credit 43 subaccount “Transferred samples”
— 13,660 rub. — the cost of two transferred product samples for certification tests was written off;
Debit 60 Credit 60 subaccount “Settlements for advances issued”
— 7670 rub. — the previously transferred advance payment for certification work has been credited;
Debit 68 subaccount “VAT calculations” Credit 19
— 1170 rub. — accepted for VAT deduction.
From June 2006 to May 2008, the following is posted monthly on the last day of the month:
Debit 20 Credit 97
— 840 rub. ((RUB 6,500 + RUB 13,660) : 2 years : 12 months x 1 month) — expenses for certification in the part attributable to the current month are expensed.
___________________________
End of example

It often happens that an organization stops producing a product before its certificate of conformity expires. In this case, the unwritten off amount of certification expenses is charged to account 91 “Other income and expenses.”

Example 2 Since May 2006, the organization has stopped producing water heaters.
In November 2004, it received a certificate of conformity for these products valid until October 31, 2006. The costs of certification amounted to 18,240 rubles. At the same time, VAT was paid to the certification body in the amount of 1,584 rubles. From November 2004 to April 2006, the organization’s accounting monthly included expenses for water heater certification in expenses for ordinary activities:
Debit 20 Credit 97
— 760 rub. (RUB 18,240: 2 years: 12 months x 1 month) – costs associated with water heater certification are taken into account.
During this period, expenses included 13,680 rubles. (760 rub./month x (2 months + 12 months + 4 months)), where 2, 12 and 4 are the number of months in 2004-2006 in which certification costs were recorded.
After the production of water heaters ceased, the remaining amount not written off was 4,560 rubles. (18,240 – 13,680) refers to other expenses:
Debit 91-2 Credit 97
— 4560 rub. – reflects the part of the costs for water heater certification that falls on the period when their production ceased (from May to October 2006).
___________________
End of example
When writing off the remaining amount of costs for product certification as other expenses, tax authorities may require the restoration and payment to the budget of the amount of VAT previously legally accepted for deduction attributable to this part of the costs. The position of the tax authorities is based on the provision established by paragraph 2 of Article 171 of the Tax Code of the Russian Federation. According to this norm, VAT amounts on goods (works, services) purchased only for carrying out transactions subject to VAT are subject to deductions. The amounts of tax charged by the seller to taxpayers on property that is not used to carry out transactions subject to VAT must be taken into account in its value (clause 2 of Article 170 of the Tax Code of the Russian Federation). Write-off of certification costs attributable to the period when the production of certified products is discontinued, according to tax authorities, means that they are no longer used to carry out operations subject to VAT. Therefore, tax amounts previously accepted for deduction on such expenses are subject to restoration.
This year, a new version of paragraph 3 of Article 170 of the Tax Code of the Russian Federation is in force. It establishes a closed list of cases when the taxpayer must restore the previously lawfully accepted VAT amount. And the case mentioned above is not there.
As we see, a controversial situation arises. And the management of the organization must make its own decisions. When choosing one or another course of action, the taxpayer must take into account all the consequences of his actions, including unfavorable ones. When choosing an option that does not coincide with the position of the tax authority, you must be prepared to defend your view in arbitration court.
Following the recommendations of tax authorities obliges the organization to take additional actions.
Continuation of example 2 The taxpayer agreed with the tax authorities’ proposal.
In accounting, the following entries are added to the above entries:
Debit 19 Credit 68 subaccount “VAT calculations”
— 396 rub. (RUB 1,584: 24 months x 6 months) – the amount of VAT attributable to unwritten off certification costs has been restored;
Debit 91-2 Credit 19
— 396 rub. – the restored amount of VAT is taken into account.
___________________________________
End of example

Organizations carrying out trading activities and purchasing goods for resale are, in some cases, required to carry out their certification. This happens when goods are imported.

If the purchased goods subject to mandatory certification have a foreign certificate that is not recognized in the Russian Federation, or there is no certificate at all, then in order to import them into the territory of the Russian Federation, you must obtain a Russian certificate of the mandatory certification system.

In this case, in accounting, the costs of mandatory certification of imported goods are included in the costs of their acquisition (clauses 5 and 6 of PBU 5/01 “Accounting for inventories”; approved by order of the Ministry of Finance of Russia dated 06/09/01 No. 44n). They form the actual cost of goods, at which goods are accepted for accounting.

Example 3 In May 2006, an organization purchases a consignment of goods from a foreign company to sell them on the territory of the Russian Federation.
The contract value of goods is 350,000 rubles, customs duty is 35,000 rubles, customs duty is 350 rubles, VAT is 69,300 rubles. Imported goods are subject to mandatory certification. To obtain a certificate, the organization entered into an agreement with a special certification body. The cost of services for mandatory certification of a consignment of goods amounted to 7,080 rubles. including VAT - 1080 rubles. To carry it out, samples of imported goods worth 3,500 rubles are presented.
In the accounting records of the organization, the posting of goods imported into the territory of the Russian Federation is reflected as follows:
Debit 60 Credit 52
— 350,000 rub. — funds for imported goods are transferred;
Debit 76 Credit 51
— 35,000 rub. — customs duties have been paid;
Debit 76 Credit 51
— 350 rub. — customs duty has been paid;
Debit 76 Credit 51
— 69,300 rub. — reflects the amount of VAT paid to the customs authority;
Debit 60 Credit 51
— 7080 rub. — funds were transferred for mandatory certification of imported goods;
Debit 41 subaccount “Goods transferred for certification” Credit 41
— 3500 rub. — the goods were transferred to the certification body for testing;
Debit 41 Credit 60
— 350,000 rub. — the contract value of the goods is taken into account;
Debit 41 Credit 76
— 35,000 rub. — the amount of customs duty paid is included in the cost of imported goods;
Debit 41 Credit 76
— 350 rub. — the cost of goods includes the amount of customs duties paid;
Debit 41 Credit 60
— 6000 rub. — the costs of mandatory certification are included in the cost of imported goods;
Debit 41 Credit 41 subaccount “Goods transferred for certification”
— 3500 rub. — the cost of goods transferred to the certification body for testing has been written off;
Debit 19 Credit 60
— 1080 rub. — reflects the amount of VAT charged by the body for certification services;
Debit 19 Credit 76
— 69,300 rub. — reflects the amount of VAT paid to the customs authority;
Debit 68 subaccount “VAT calculations” Credit 19
— 70,380 rub. (69 300 + 1080) - VAT paid to the customs authority and certification body is accepted for deduction.
The cost of a consignment of goods imported into the Russian Federation will be 394,850 rubles. (350,000 + 35,000 + 350 + 6000 - 3500).
______________________________________
End of example

Trade organizations can carry out voluntary certification of goods purchased for resale even after they have been accepted for registration. In this case, certification costs should be reflected as expenses for ordinary activities.

If the certificate is issued for a specific batch of goods, its validity period is not established. It is limited by the shelf life of the goods for which such a certificate is issued.

Example 4 An organization engaged in wholesale trade purchased goods in April 2006 that are not subject to mandatory certification.
The supplier was paid 212,400 rubles for them. including VAT - RUB 32,400. In May, she decided to obtain a certificate of conformity for the product. For services to the certification body, 5,900 rubles were transferred, including VAT - 900 rubles. In accounting, when reflecting these transactions, the following entries are made.
In April:
Debit 60 Credit 51
— 212,400 rub. — funds were transferred to pay for goods;
Debit 41 Credit 60
— 180,000 rub. — goods are capitalized;
Debit 19 Credit 60
— 32,400 rub. — VAT on purchased goods is taken into account;
Debit 68 subaccount “VAT calculations” Credit 19
— 32,400 rub. — accepted for deduction of VAT on purchased goods.
In May:
Debit 60 subaccount “Settlements on advances issued” Credit 51
— 5900 rub. — funds were transferred to the body conducting certification tests;
Debit 97 Credit 60
— 5000 rub. — reflects the cost of the received certificate of conformity;
Debit 19 Credit 60
— 900 rub. — the amount of VAT on certification services has been allocated;
Debit 60 Credit 60 subaccount “Settlements for advances issued”
— 5900 rub. — advance payment credited;
Debit 68 subaccount “VAT calculations” Credit 19
— 900 rub. — claimed for deduction of VAT on certification costs.
Certification costs recorded on account 97 are written off as sales expenses as the goods of this batch are sold:
Debit 44 Credit 97
— the costs of certification of this batch of goods are taken into account.
__________________________
End of example

Tax accounting of expenses

In tax accounting, certification costs are classified as other expenses associated with production and sales (subclause 2, clause 1, article 264 of the Tax Code of the Russian Federation). Moreover, under this expense item it is possible to take into account the costs of both mandatory and voluntary certification, since the legislator in the Tax Code of the Russian Federation has not established restrictions on this type of expense. Thus, the costs of certification: voluntary and mandatory, are recognized in tax accounting provided that they are economically justified.

The Tax Department in the canceled Methodological Recommendations for the application of Chapter 25 “Income Tax of Organizations” of Part Two of the Tax Code of the Russian Federation (approved by order of the Ministry of Taxes of Russia dated December 20, 2002 No. BG-3-02/729, canceled by order of the Federal Tax Service of Russia dated April 21, 2005 No. SAE-3-02/173) believed that the costs of certification, which were carried out in accordance with the then-current Law of the Russian Federation of June 10, 1993 No. 5151-1 “On Certification of Products and Services,” are considered economically justified (clause 2 of section 5.4 .recommendations). Since Law No. 5151-1 lost force from the date of entry into force of Federal Law No. 184-FZ - July 1, 2003, tax authorities should not have doubts about the costs of certification, which were carried out in the manner established by Law No. 184-FZ .

The tax authorities recommended including these expenses as expenses of the current period during the period for which the certificate was issued. Therefore, the amounts of certification costs, attributed in example 1 in accounting to expenses for ordinary activities, will coincide with the amounts included in other expenses in tax accounting. In examples 3 and 4, such a coincidence is also possible if the accounting policy for tax purposes of the organization establishes the inclusion of costs for certification of goods in their initial cost. Let us recall that the taxpayer has the right to independently determine the cost of purchased goods, taking into account the costs associated with their acquisition (Article 320 of the Tax Code of the Russian Federation).

Taking into account in non-operating expenses in tax accounting part of the costs of certification of products attributable to the period when its production is discontinued (example 2) is more likely to cause a negative attitude among tax officials. They will consider such costs to be economically unjustified.

Following their wishes obliges the organization to turn to the norms of PBU 18/02 “Accounting for income tax calculations” (approved by order of the Ministry of Finance of Russia dated November 19, 2002 N 114n). The resulting difference in expenses in accounting and tax accounting is recognized as constant, since it is not taken into account when calculating the tax base for income tax both in the reporting period and in subsequent periods. Therefore, a permanent tax liability is accrued in accounting (clause 4-7 of PBU 18/02):

Debit 99 Credit 68 subaccount “Calculations for income tax”

– 1094.40 rub. (RUB 4,560 x 24%) - a permanent tax liability has been accrued.

If we also take into account the restored amount of VAT, then the value of the permanent tax liability will reach 1189.44 rubles. (RUB 1,094.40 + RUB 95.04 (RUB 396 x 24%)).

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