Bakers, confectioners and some other categories of enterprises that purchase grain processing products for retail sale to individuals, as well as for the production of products that are not traceable in the FSIS “Grain”, do not need to register and record business transactions in the system. For such categories of enterprises, suppliers of raw materials will form SDIZ in the system, but it will not be necessary for bakers and confectioners to repay them, according to the Center for Agroanalytics.
However, there are nuances, the system operator clarifies.
You must register in the system if the company:
- produces grain processing products (for example, it is a miller or a producer of cereals, etc.);
- transports purchased grain processing products (for example, transports between own storage locations);
- purchases grain processing products for the production of products that can be traced in the system (for example, it produces gluten from flour or a mixture of cereals from different cereals);
- sells grain processing products to other legal entities (for example, carries out wholesale deliveries).
Such organizations must form batches of grain or grain processing products in the system and work with them (combine, separate, write off, etc.), pay off incoming SDIZ and issue outgoing ones.
It is not necessary to register in the system (in accordance with part 4 of Article 17.1 of the Law of the Russian Federation of May 14, 1993 No. 4973-1 “On Grain”) if the enterprise:
- purchases grain processing products for sale to individuals, i.e. sells them at retail (for example, a convenience store, a market, etc.);
- purchases processed grain products for the production of products that are not traceable in the system (for example, it produces bakery or confectionery products).
In this case, the SDIZ issued to the organization will not be extinguished by it, since it may not enter the system.
Manufacturers of ready-made breakfasts, as enterprises that purchase grain and grain processing products that are traceable in the system (cereals), still need to register with the FSIS “Grain”. They will need to create and repay SDIZ there.
Thus, the need to register in the system depends on the business processes of the organization. If an organization performs any transactions with grain, then its registration in the system is still required. Some exceptions apply only to processed grain products.
