Summary: Conformity Assessment of Industrial Plants and Industrial Safety (HIF/OPO)
- Integrated conformity approach for industrial plants: Modern production lines, process skids, and turnkey industrial installations in the EAEU are governed by an interplay of multiple Technical Regulations (notably TR CU 010/2011 for machinery safety, TR CU 004/2011 for low-voltage equipment, TR CU 020/2011 for electromagnetic compatibility, TR EAEU 037/2016 for RoHS restrictions, TR CU 012/2011 for explosion protection, and TR CU 032/2013 for pressure equipment).
- Specific requirements for Hazardous Industrial Facilities (HIF / OPO):
- Technical classification criteria under Federal Law No. 116-FZ: Mandatory for facilities operating pressure equipment exceeding 0.07 MPa, hot water systems above 115 °C, stationary hoisting machinery, molten metal furnaces handling 500 kg or more, or handling hazardous, toxic, and explosive substances or dusts.
- Scheme 5d under TR CU 010/2011: The mandatory declaration scheme for machinery and process lines deployed at hazardous industrial facilities where full conformity verification is only feasible on-site after final assembly, or where harmonized GOST standards were not applied during design. It strictly requires an official Certificate of Type Examination issued by an accredited certification body.
- Mandatory hard-copy documentation for HIF/OPO: While electronic operating documentation is generally permitted across standard EAEU machinery sectors, equipment deployed at hazardous production facilities (HIF / OPO) remains subject to a strict statutory requirement to provide the Operating Manual and Technical Passport in printed paper format.
- Demarcation between EAC conformity and Industrial Safety Review (EPB): In the Russian Federation, newly manufactured equipment covered by EAEU Technical Regulations and accompanied by a valid EAC Certificate or EAC Declaration is exempt from a separate pre-commissioning Industrial Safety Review (EPB) under Art. 7 of Federal Law No. 116-FZ. An EPB pursuant to Rostechnadzor Federal Safety Rules (Order No. 420) is required primarily for legacy equipment, post-modification, upon reaching design service life (or after 20 years of operation), or for non-regulated bespoke machinery.
- National regulatory regimes (Kazakhstan & Belarus):
- Republic of Kazakhstan: Operating hazardous technical devices at hazardous industrial facilities requires a statutory Permit to Use issued by the Industrial Safety Committee of the Ministry of Emergency Situations (MChS RK) pursuant to Art. 74 of Law No. 188-V, substantiated by an accredited Industrial Safety Review report.
- Republic of Belarus: Technical equipment installed at hazardous or potentially hazardous industrial facilities is subject to oversight by Gospromnadzor under Law No. 354-Z on Industrial Safety.
- Regulatory interface between TR CU 004/2011 and machinery: Electrical components forming an integral, factory-installed part of machinery governed by TR CU 010/2011 or TR CU 012/2011 are exempt from separate low-voltage certification. Exception: Separately dispatched power cables, wiring harnesses, and standalone switchgear assemblies remain subject to mandatory certification under TR CU 004/2011.
- Ten-year archival obligation: The authorized representative must securely retain the complete technical dossier (Safety Justification, test reports, Certificate of Type Examination) for at least 10 years after the expiration of the declaration's validity.
- Sanctions compliance via Kazakhstan: Schmidt & Schmidt coordinates the safety and regulatory conformity of industrial installations through its fully operational offices in Kazakhstan, providing European plant manufacturers with legally robust market access in full compliance with EU and US export control regulations (including Council Regulation (EU) No 833/2014).
Conformity Assessment of Industrial Plants: The Comprehensive Regulatory Framework in EAEU Law
Industrial production lines, manufacturing plants, and integrated process skids in mechanical and plant engineering consist of numerous interconnected machines, pressure vessels, electrical control cabinets, and piping networks. Exporting these complex systems to the member states of the Eurasian Economic Union (Russia, Kazakhstan, Belarus, Armenia, Kyrgyzstan) involves navigating a multi-layered regulatory architecture:
Baseline product safety is evaluated supranationally under the Technical Regulations of the EAEU, culminating in the issuance of an EAC Certificate or the registration of an EAC Declaration. However, when these industrial plants are destined for high-risk operating environments—classified as Hazardous Industrial Facilities (HIF / OPO) in the oil, gas, chemical, metallurgical, or mining sectors—national Industrial Safety legislation applies in tandem.
Schmidt & Schmidt provides plant manufacturers and EPC contractors with turnkey regulatory management—from initial component classification and factory audits to securing national operating permits and statutory registry entries.
Harmonized EAEU Technical Regulations for Machinery and Plant Engineering
Because modern industrial plants combine multiple functional subsystems, relying on a single technical regulation is rarely sufficient. Depending on the assembly and operational parameters, several regulations apply concurrently:
| Technical Regulation | Scope for Industrial Plants | Typical Conformity Format |
|---|---|---|
| TR CU 010/2011 Safety of Machinery and Equipment |
Primary regulation for mechanical safety, drives, presses, material handling systems, and complete lines. Requires the mandatory compilation of a Safety Justification (OB). | EAC Declaration (Schemes 1d, 3d, 5d, 6d) or EAC Certificate (Schemes 1c, 3c). |
| TR CU 004/2011 Low-Voltage Equipment (LVD) |
Electric motors, drive assemblies, power distribution units, and control cabinets rated between 50–1,000 V AC or 75–1,500 V DC. | EAC Certificate (for standalone panels/cables) or EAC Declaration. Does not apply to built-in integral machine parts (Art. 1). |
| TR CU 020/2011 Electromagnetic Compatibility (EMC) |
Electronic control systems, variable frequency drives (VFDs), industrial PCs, sensors, and PLC racks regarding electromagnetic emissions and immunity. | EAC Declaration (can be voluntarily upgraded to an EAC Certificate). |
| TR EAEU 037/2016 RoHS Restrictions |
Electronic control modules, instrumentation transmitters, switching relays, and cabling regarding concentration limits of lead, mercury, cadmium, and flame retardants. | EAC Declaration (Schemes 1d, 2d, 3d, 4d, 6d). |
| TR CU 032/2013 Pressure Equipment |
Pressure vessels, heat exchangers, industrial boilers, process piping, and safety relief valves operating at overpressures > 0.05 MPa. Classified into hazard categories 1 to 4. | Categories 1 & 2: EAC Declaration. Categories 3 & 4: EAC Certificate. |
| TR CU 012/2011 Explosion Protection (ATEX/Ex) |
Electrical and non-electrical equipment and safety systems deployed in potentially explosive gas or dust atmospheres (refineries, chemical processing, storage silos). | Exclusively EAC Ex Certificate (declarations are strictly prohibited by law). |
| TR CU 016/2011 Gas-Fired Appliances |
Industrial gas burners, process heaters, and thermal oxidizer systems fired by gaseous fuels. | EAC Certificate or EAC Declaration. |
Switchgear, Control Cabinets, and Electrical Interfaces
Switchgear, Motor Control Centers (MCC), and PLC automation cabinets constitute the electrical backbone of automated production plants. They distribute electrical power, govern drive systems, and manage process automation. When supplied as pre-assembled functional units, distinct regulatory boundaries must be observed:
- Regulatory boundary under Art. 1 TR CU 004/2011: Electrical equipment built directly and integrally into machinery covered by TR CU 010/2011 or TR CU 012/2011 falls within the conformity assessment of the machine as a whole and does not require standalone TR CU 004 certification as an integrated sub-assembly.
- Independent status of separate switchgear and cabling: When power cables, industrial wiring, or standalone power distribution boards are delivered as separate customs items (discrete HS code positions), they are subject to mandatory EAC Certification under TR CU 004/2011.
- Electromagnetic compatibility (TR CU 020/2011): Active digital components (PLCs, inverters, power supply units, touch panels) require an EAC Declaration, which is typically co-certified alongside the safety dossiers.
- Hazardous substance restriction (TR EAEU 037/2016): Mandatory proof of RoHS compliance covering all internal wiring, relays, terminal strips, and electronic modules.
- Medium and high voltage (> 1,000 V AC): Because medium-voltage switchgear is outside the scope of TR CU 004, it is governed by national regulatory regimes (e.g., Russian GOST R certification pursuant to Government Decree No. 2425 or Kazakhstan's GOST K system).
Hazardous Industrial Facilities (HIF / OPO): Technical Criteria & Scheme 5d
Industrial installations operating in refineries, petrochemical plants, metallurgical mills, thermal power stations, and underground mining are legally defined as Hazardous Industrial Facilities (in Russian: Опасные производственные объекты – ОПО). They are subject to stringent government controls to prevent industrial accidents, environmental contamination, and occupational hazards.
Technical Classification Criteria for HIF / OPO (Annex 1 to Federal Law No. 116-FZ)
An industrial manufacturing facility is legally categorized as a hazardous facility if at least one of the following technical criteria or processes is present on-site:
| Technical Parameter | Statutory Thresholds and Facility Types |
|---|---|
| Handling of Hazardous Substances | Production, use, processing, storage, or transportation of flammable gases, combustible liquids, toxic and highly toxic chemicals, oxidizing agents, commercial explosives, and environmentally hazardous substances exceeding the statutory threshold quantities set out in Annex 2 of Law No. 116-FZ. |
| Thermal and Pressurized Media | Operation of pressure vessels, boilers, autoclaves, and process piping operating at an overpressure exceeding 0.07 MPa (0.7 bar) involving:
|
| Stationary Hoisting Machinery | Deployment of permanently installed lifting equipment, overhead gantry cranes, process cranes (excluding standard passenger elevators), industrial funiculars, cableways, and escalators. |
| Metallurgical Melts | Production, processing, and handling of molten ferrous and non-ferrous metals and specialized alloys using furnace and ladle equipment rated for a batch melting capacity of 500 kg or more. |
| Mining & Underground Works | Underground and surface mining, mineral processing, shaft sinking, tunneling, and geological exploration involving industrial blasting agents. |
| Explosive Dusts & Agricultural Bulk Materials | Storage or processing of grain, oilseeds, agricultural feedstuffs, and vegetable bulk raw materials capable of generating explosive dust-air mixtures susceptible to self-heating, spontaneous combustion, or deflagration. |
Depending on potential accident severity, facilities are classified into four hazard categories: Class I (extremely high hazard), Class II (high hazard), Class III (medium hazard), and Class IV (low hazard). This classification determines the regulatory inspection cycle and mandatory civil liability insurance coverage.
Special Declaration Scheme 5d under TR CU 010/2011 for HIF / OPO Equipment
Under TR CU 010/2011, Declaration Scheme 5d is legally mandatory for machines and industrial lines that:
- Are operated at Hazardous Industrial Facilities (HIF / OPO); and/or
- Due to overall dimensions, process complexity, or modular shipping, cannot be fully tested as an integrated assembly at the manufacturer's plant prior to dispatch, requiring final assembly and commissioning at the operating site; and/or
- Were designed and engineered without the direct application of harmonized EAEU GOST standards (custom-built or specialized machinery).
Procedural flow for Scheme 5d:
The manufacturer or their designated Authorized Representative cannot register the declaration based merely on in-house factory test records. An accredited certification body must execute a comprehensive formal examination of the Safety Justification (Обоснование безопасности) and complete engineering dossiers to issue an official Certificate of Type Examination (in Russian: Сертификат на тип). Only upon issuance of this statutory certificate can the legally binding EAC Declaration be registered in the state database.
National Supervision & Industrial Safety Reviews (EPB)
Russian Federation
Rostechnadzor / Law No. 116-FZ
Relationship between EAC and Rostechnadzor: Pursuant to Art. 7 of Federal Law No. 116-FZ, newly manufactured equipment covered by EAEU Technical Regulations and possessing an EAC conformity certificate or declaration is exempt from a separate pre-commissioning Industrial Safety Review (EPB).
When is an EPB mandatory? Under the Federal Safety Rules (Order No. 420 of October 20, 2020), an EPB registered with Rostechnadzor is mandatory:
- For equipment not covered by any EAEU Technical Regulation;
- Upon expiry of the manufacturer's designed operational lifetime (or after 20 years of operation);
- Following structural modifications, load-bearing welding repairs, or major industrial accidents.
Republic of Kazakhstan
MChS RK / Law No. 188-V
Permit to Use: Under Art. 74 of the Law "On Civil Protection," hazardous technical equipment and technologies deployed at hazardous facilities must obtain an official Permit to Use from the Industrial Safety Committee of the Ministry of Emergency Situations (MChS RK).
Prerequisite: Execution of an Industrial Safety Review by an expert organization holding a state license in Kazakhstan.
Validity: Issued electronically in the state registry and remains valid indefinitely for the approved equipment type.
Republic of Belarus
Gospromnadzor / Law No. 354-Z
Supervision by Gospromnadzor: The Law "On Industrial Safety" governs the commissioning and operation of technical equipment at hazardous and potentially hazardous production facilities.
Permit procedure: Certain regulated plant equipment (cranes, high-pressure vessels, pipelines) requires a formal operating permit from Gospromnadzor prior to commissioning.
Registration: The industrial installation must be entered into the state register of hazardous production facilities.
Procedure for Obtaining a Permit to Use in Kazakhstan
Unlike the Russian Federation, Law No. 188-V of the Republic of Kazakhstan "On Civil Protection" (Article 74) requires technical equipment used at hazardous industrial facilities to obtain a separate state operating approval (in Russian: Разрешение на применение). This administrative procedure follows six distinct stages:
-
Compilation and Engineering Review of Technical Dossiers:
The manufacturer or project operator prepares the technical files. These include detailed functional descriptions, operating manuals, the Technical Passport drafted to GOST standards, assembly drawings, mechanical strength calculations, material and weld inspection certificates, and existing EAC conformity documents. -
Engagement of an Accredited Expert Organization:
The review must be conducted by an engineering entity domiciled in Kazakhstan holding an active state license issued by the Ministry of Emergency Situations (MChS RK) for industrial safety assessments. -
Execution of the Industrial Safety Review:
Licensed safety experts evaluate the engineering design against Kazakh national safety standards. For highly complex custom lines or serial approvals, on-site manufacturing audits or witness testing at the factory may be required. -
Issuance and State Registration of the Expert Report:
Upon successful technical evaluation, the licensed organization issues an official Industrial Safety Review Report (in Russian: Экспертное заключение промышленной безопасности) certifying that the technical device complies with occupational safety and accident prevention standards. -
Filing with the Industrial Safety Committee (MChS RK):
The expert report, accompanied by the formal petition and equipment specifications, is submitted electronically through Kazakhstan's e-government portal to the Industrial Safety Committee of MChS RK. -
Government Review and Issuance of the Permit to Use:
The ministry evaluates the application. Upon confirmation of compliance, MChS RK issues the formal decree and records the permit in the electronic state register of Permits to Use. The permit is issued digitally with an authorized digital signature (EDS) and carries indefinite validity for the certified equipment model.
Mandatory Technical Documentation under GOST Standards
For industrial plant conformity assessment and on-site commissioning at hazardous facilities, all engineering documentation must adhere to intergovernmental GOST standards and be drafted in the Russian language (as well as the state language of the destination country where required):
- Safety Justification (Обоснование безопасности – OB): Drafted pursuant to GOST 33855-2016. A mandatory key document for machinery under TR CU 010/2011 and pressure equipment under TR CU 032/2013 containing risk assessments across all operational lifecycle stages.
- Technical Passport (Паспорт – PS): Drafted according to GOST 2.601 / GOST 2.610. The official operational log of the plant detailing design parameters, operating thresholds, material certificates, weld inspection logs, and commissioning sign-offs.
- Operating Manual (Руководство по эксплуатации – RE): Comprehensive instructions governing assembly, initial startup, maintenance intervals, safety interlocks, and emergency shutdown procedures.
- Mechanical Strength Calculations (Расчет на прочность): Structural and pressure calculations for components governed by TR CU 032/2013, as well as seismic and static load calculations for supporting steel structures.
- P&ID and Electrical Schematics: Piping and instrumentation diagrams, single-line wiring diagrams, terminal connection lists, and functional safety instrument loops.
The Certification Matrix for Turnkey and EPC Projects
During the engineering and procurement of integrated industrial plants, chemical process skids, or refinery units, managing hundreds of sub-component certificates without structured coordination creates significant compliance vulnerabilities. Schmidt & Schmidt establishes a comprehensive, multi-vendor Certification Matrix at project kick-off:
| Plant Component | HS Tariff Code | Applicable Regulations / Laws | Required Compliance Document | Status |
|---|---|---|---|---|
| Integrated Process Line | 8479 / 8419 | TR CU 010/2011 (HIF / OPO Deployment) | EAC Declaration under Scheme 5d + Type Examination Certificate | In Progress |
| Main Control Cabinet (MCC) | 8537 | TR CU 004/2011, TR CU 020/2011, TR EAEU 037/2016 | EAC Certificate (004) + EAC Declaration (020, 037) | Completed |
| Reactor Pressure Vessel (Cat. 4) | 7311 / 8419 | TR CU 032/2013 | EAC Certificate under Scheme 1c (Factory Audit) | Audit Scheduled |
| Ex-Proof Flowmeter | 9026 | TR CU 012/2011, Legal Metrology | EAC Ex Certificate + Pattern Approval (PAC) | Lab Commissioned |
| Emergency Shutdown Valve (SIL 3) | 8481 | TR CU 010/2011, TR CU 032/2013 | EAC Declaration + Mechanical Calculations | Files Approved |
The Authorized Representative in the EAEU
Foreign plant manufacturers without an incorporated legal entity established within the customs territory of the EAEU are legally barred from registering EAC declarations in official government databases. The contractual appointment of an Authorized Representative resident in the Union is mandatory under EAEU law.
Schmidt & Schmidt serves as an independent, neutral Authorized Representative. This structure ensures that all certification titles, test records, and registration rights remain fully under your control as the manufacturer, avoiding commercial dependency on local distributors or general contractors.
Statutory 10-Year Recordkeeping: Under Article 8 of TR CU 010/2011, the Authorized Representative is legally bound to securely archive the complete evidentiary dossier (Safety Justification, Type Examination Certificates, accredited test reports) for at least 10 years following the expiration date of the conformity certificate or declaration, making it available to market surveillance authorities upon request.
Sanctions Compliance for Industrial Plants & Plant Engineering
Complete industrial installations, heavy compressors, turbine packages, high-pressure pumps, severe-service valves, and automation systems are subject to stringent export control restrictions enacted by the European Union (Council Regulation (EU) No 833/2014) and the United States. Substantial portions of advanced industrial equipment are listed under Annex VII (Dual-Use) or Annex XXIII (Industrial Goods Embargo).
Furthermore, supplies destined for state-owned or designated enterprises in the energy, petrochemical, mining, or metallurgical sectors, as well as financial transactions involving SDN-listed financial institutions, are prohibited. Capital projects require rigorous end-use and end-user verification.
Legal certainty through Kazakhstan: Schmidt & Schmidt operates fully staffed corporate offices in Almaty and Astana. As a founding member state of the EAEU, Kazakhstan maintains accredited testing institutes and regulatory bodies fully recognized across the customs union. We enable European equipment manufacturers to conduct legitimate certification workflows and project management in strict adherence to European export control frameworks.
Further guidance: EAC Certification and Regulatory Compliance under International Sanctions.
Timeline, Costs, and Delivery of Original Certificates
Timelines and costs for the conformity assessment of industrial plants depend on the applicable certification schemes and testing scope:
- EAC Declaration (Standard): Processing timeline approximately 1 to 2 weeks.
- EAC Certification under TR CU 010 / 004 / 012 / 032 (Series): Processing timeline approximately 6 to 9 weeks (including manufacturing audit and laboratory testing).
- EAC Declaration under Scheme 5d (HIF / OPO): Processing timeline approximately 4 to 8 weeks (including engineering assessment and issuance of the Certificate of Type Examination).
- Permit to Use in Kazakhstan (MChS): Processing timeline approximately 2 to 3 months (including execution of the statutory Industrial Safety Review).
- Validity terms: Certificates and declarations for serial production are issued for 1 to 5 years. For single batch or project contracts, validity is tied to the contract duration and covers the specific serial numbers indefinitely.
How Does Industrial Plant Certification Work with Schmidt & Schmidt?
We manage your plant engineering compliance from early design review through to final on-site commissioning release:
