Product Certification for Eurasian Economic Union

Eurasian Economic Union (EAEU) is a consolidation of former CIS countries — Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia.

EAEU has a single Customs Code and a single system of technical regulations, which are conceptually similar to the CE directives and are often based on international standards, but have a number of significant differences in procedures.

The common approval mark of the EAEU technical regulation system is the EAC mark.

"EAC" stands for "Eurasian Conformity", and the obtaining of the EAEU approvals is usually referred to as "EAC certification", regardless of actual form of the approval — certification of conformity, declaration of conformity or otherwise.

Products that have obtained the approvals of the EAEU technical regulations must be marked by the EAC sign before passing the customs clearance. Then, products marked with the EAC can freely circulate throughout the territory of the EAEU.

Determining if EAC approval is required

EAC is mandatory for vast list of products.

There are over 50 active Technical Regulations commonly referred to as CU TR and EAEU TR, or TR CU and TR EAEU. Products not regulated by the EAC system may be subject to national approvals in each country of the EAEU.

Whether or not a product is subject to EAC approval depends on the following details:

1. Product type and designation,
2. Its functions and characteristics,
3. HS tariff code.

For products subject to one or several Regulations the assessment of conformity is mandatory. Products that have not passed the established procedures cannot be marked with the EAC sign of conformity, and are not allowed for import on the territory of the EAEU.

EAC approvals may not be required for testing and exhibition samples, souvenirs or promotional materials, spare parts and accessories, humanitarian aid, used products and products imported for personal needs.

Certain products may not be subject to mandatory approvals due to their characteristics, but it may not be obvious to Customs service officials, or other parties in the supply chain. In such cases, importers may use Letters of Exemption or Negative decisions to support the them in the potential disputes with the customs authorities.

Obtaining the EAC approvals

The main types of EAC approval documents are:

1. EAC Declaration of conformity based on the own evidence of the manufacturer,
2. EAC Declaration of conformity based on local testing,
3. EAC Certificate of conformity,
4. State Registration certificate,
5. Vehicle design safety certificate and Chassis Type approval.

Depending on the type of approval, the required procedures to obtain the EAC mark may include:

1. Customs clearance of the sample,
2. Sample testing,
3. Use of existing proof,
4. Factory inspection,
5. Development, audit and translation of technical documentation,
6. Periodic inspections.

The turnaround time to obtain an EAC approval may vary from 3-5 days to 2-3 months, depending on the product, requirements, availability of the necessary materials and documents.

In certain cases, EAC declarations can be obtained based on the factory test reports and other existing evidence of the manufacturer. To be accepted, these documents need to demonstrate conformity to the requirements of the regulations, and to be translated into Russian.

Who can issue EAC approvals

The testing is conducted and approvals are issued by testing labs and certification bodies duly accredited by the relevant national accreditation institutions:

National Accreditation Body of Armenia

Belarusian State Center for Accreditation

National Accreditation Center in Kazakhstan

Kyrgyz Center for Accreditation

Federal Accreditation Service in Russia

* In Russia, declarations of conformity for most products are registered directly by the Local Applicant, not involving a certification body.

Local applicant for EAC approvals

There are two parties in the EAC approvals — the Manufacturer and the Local Applicant. The Local Applicant is always a legal entity that is a resident of the EAEU, either an importer of the shipment, acting on the basis of the shipment contract, or a representative of the foreign Manufacturer in the EAEU, called Local Applicant.

Local Applicant is representing the foreign Manufacturer in the EAEU based on the Representation agreement in terms of compliance of the product, and is mandatory for long-term approvals to hold legal responsibility for the conformity of the products to the technical regulations.

A third-party Applicant may be used to avoid the common bottlenecks of a particular distributor monopolizing the right to use the approvals, and avoid the need to obtain several approvals for the same product.

By obtaining certification independently, i.e. in the name of the third-party Applicant, the Manufacturer retains control over the EAC certification, and the rights to distribute approvals to the distributors or customers of choice.

Validity of EAC approvals

The maximum validity period is determined in each Regulation and may vary from 3 to 5 years.

Certificates of conformity require annual inspections to remain valid, and may take the form of repeated sample testing, or factory inspection, or both.

For single shipments, the validity is limited by the quantity of imported products, which is indicated directly in the certificate or declaration of conformity, as well as the invoice and contract details.

Steps to acquire EAC certification

1. Categorize your product according to the pertinent regulation to determine the form of approval and the required procedures.

1. Gather the necessary documentation, such as a technical passport, safety justification, safety datasheets, test reports, operation manual, representation contract and the local representative statutory documents.
2. Ensure all your technical documentation is in order and, if required, translate the documents into Russian.
3. Factory audit, sample selection, import, customs clearance and testing, if applicable.
4. The Approval is registered in the public registers, printed out on paper and validated by the signing party — certification body expert or the Local Applicant.
5. Affix the EAC marking to your product respecting the size, visibility and durability requirements.

Cost of EAC certification

The costs are primarily determined by the product's classification, applicable regulations, required procedures such as factory inspection, local testing, and annual inspections, and also the quality of the available documentation.

Many times improper classification and nonoptimal grouping will lead to increased costs and timing.

To provide a detailed quote, we shall need to study the product details and the available documentation. Generally, a quote for the certification procedure is ready within 1-2 working days, given all the necessary information is at hand.

List of products subject to EAC approvals

1. Machinery and equipment,
2. Low-voltage equipment,
3. High-voltage equipment,
4. Appliances operating on gaseous fuel,
5. Equipment operating under excessive pressure,
6. Vessels operating under pressure,
7. Equipment for working in explosive atmospheres,
8. Amusement rides, equipment for children's playgrounds,
9. Lifts,
10. Wheeled vehicles,
11. Tractors,
12. Agricultural machinery,
13. Machinery for forestry,
14. Tires,
15. Rolling stock of railway transport, including high-speed,
16. Metro rolling stock,
17. Light rail transport, trams,
18. Maritime transport facilities,
19. Inland water transport facilities,
20. Small craft,
21. Buildings and facilities,
22. Building materials and products,
23. Rail infrastructure, including high speed,
24. Metropolitan infrastructure,
25. Roads,
26. Pyrotechnic compositions and products containing them,
27. Explosives for civilian use and products containing them,
28. Light industry products (finished goods, carpets and rugs, knitwear, sewing and leather goods; footwear; fur and fur products),
29. Toys,
30. Products for children and adolescents,
31. Baby care products,
32. Dishes,
33. Sanitary hygiene products,
34. Perfume and cosmetic products,
35. Oral hygiene products,
36. Tare and packaging,
37. Personal protective equipment,
38. Fire safety equipment,
39. Fire extinguishing agents,
40. Medical products,
41. Sanitary wares,
42. Furniture products,
43. Chemical products,
44. Synthetic detergents,
45. Household chemicals,
46. Paintwork materials and solvents,
47. Fertilizers,
48. Plant Protection Products,
49. Gasoline, diesel and marine fuel, jet fuel and fuel oil,
50. Lubricants, oils and special liquids,
51. Apparatus and systems for metering of water, gas, thermal energy, electric energy,
52. Apparatus and systems for metering of oil, products of its processing,
53. Food products,
54. Alcohol products,
55. Fodder and feed additives,
56. Grain,
57. Tobacco products,
58. Hunting and sporting weapons, ammunition to it,
59. Telecommunication equipment,
60. Coal and its products,
61. Liquefied hydrocarbon gases for use as fuel,
62. Materials in contact with human skin,
63. Products intended for civil defense and protection from natural and man-made emergencies,
64. Oil prepared for transportation and / or use,
65. Combustible natural gas first prepared for transportation and (or) use,
66. Pipelines for transporting of liquid or gaseous hydrocarbons.

Documents of the unified form of the EAEU

For a number of products that are not subject to either EAC regulations or national requirements, a free circulation of certified goods on the territory of the EAEU is still possible. This is a kind of artifact of interstate technical regulation in the Customs Union (the predecessor of the Eurasian Economic Union) — Decision of the Commission of the Customs Union N 620 of April 7, 2011.

This includes:

• alkaline and acid batteries,
• sand, crushed stone for road construction,
• tractors, trailers and tractor semi-trailers,
• cigarettes,
• glassware, ceramics,
• compound feed and feed additives,
• detergents, powders, tablets, gels, pastes, liquids, soap,
• bathtubs, hoses,
• canned fish products,
• matches.

The list is ever shrinking, as more and more product categories are excluded over time, but is still a helpful tool in some cases.