The market of the EAEU countries has long been gaining popularity among European manufacturers. In order to be allowed to sell the goods on the EAWU market, a number of mandatory conformity assessment procedures must be successfully completed.
Besides the EAC certificate some of the Technical Regulations of the EAEU provide for the EAC Declaration as a type of conformity assessment. The main difference is, that the EAC declaration, unlike the EAC certificate, is created and issued by the applicant himself. Both, the declaration and the certificate have the same legal validity.
The procedure of conformity assessment is often a highly complex and time-consuming process that raises many questions for manufacturers and importers. This article aims to help to find answers for these questions. All information provided in this article, bases on the Law № 184 of the Russian Federation "On Technical Regulation" of december 27, 2002 and on the GOST standard 31893-2012 Conformity assessment. Standard system in conformity assessment”.
Steps of the EAC declaration process
- Step: Classification of the product and selection of the relevant standards
- Step: Selection of the scheme of EAC declaration according to which the conformity assessment procedure is carried out
- Step: Conducting tests
- Steps: Preparation of the required documentation if the results are positive
- Step: Issuance of the EAC declaration
- Step: Entry of the declaration and the documents in the Unified Register of the Eurasian Economic Union
Classification of the product and selection of the relevant standards
The registration of an EAC declaration may only be carried out by a company established on the territory of the Eurasian Economic Union. Therefore an authorised representative within the Eurasian Economic Union is required.
If you need an authorized representative, we would be happy to offer you a suitable company to take over this function.
An EAC declaration is issued by a national manufacturer, importer or an authorized representative of a foreign manufacturer. Therefore, the responsibility for the correct classification of the products, the selection of the scheme as well as the execution of the documentation lies with the applicant itself.
All technical regulations contain descriptions of the EAC certification procedure, the so called schemes. The selection of the scheme and therefore the type of the EAC certification procedure depends on the characteristics of the products, the type of production and shipment. The scheme of the EAC declaration is selected by the applicant himself. The schemes of the conformity assessment represent the counterpart of the modules of the conformity assessment according to the EU guidline 768/2008/EG in the Eurasian Economic Union.
The testing of product samples is often a mandatory step in the EAC declaration process. A representative sample of the product is tested for conformity with the requirements of the technical regulations of the EAEU. It is also examined whether the product is suitable for the intended use.
In the case of an EAC declaration, the applicant has to send samples to a laboratory to conduct tests. Damit Musterware auch als solche akzeptiert wird, sollten gewisse Vorgaben eingehalten werden. It is easiest to send the samples as a postal item. Therefore some requirements must be met. More tips that can help the manufacturer select and ship samples can be found here.
The sample tests may be conducted on the manufacturer’s site and with the manufacturer’s testing equipment. If the EAC declaration is carried out according to scheme 1D or 2D, product tests may be carried out in the manufacturer*s own production laboratory. However, the technical regulations must be taken into account.
The tests are carried out in accordance with the standards specified in the Annex to the Technical Regulations (GOST standards) according to a special programme and methodology established on the basis of the generally accepted method of certification testing and depending on the type of product. The programme and methodology can be developed both by the manufacturer and by the experts of the certification body.
The results of the examinations are entered in the test report.
If the result is positive, the following information and documents must be prepared and collected:
- denomination of the product
- detailed product description
- customs tariff number
- technical passport
- instruction manual
- technical drawing
- technical data sheet
- test report
- registration number of the customs declaration for the import of product samples
- GLN - Global Location Number
- GTIN-Code - Global Trade Item Number
- already existing certificates: ISO, DIN, CE, CB
In any case, a detailed list of the documents which can be found in the respective technical regulation shall be indicated.
Issuance of the EAC declaration
After carrying out all the procedures above described, the applicant provides information about the product on a sheet of paper, then signs and stamps the completed paper. Currently there is no specific form for the EAC declaration.
Entry of the Declaration and the documents in the unique register of the Eurasian Economic Union
The EAC declaration is then entered by the applicant in the unified register, where it is assigned a registration number.
The period of validity of the EAC declaration depends on many parameters (for example the applied technical standards, the selected scheme and the type of production (serial production, single production etc.), which are directly specified in the respective technical regulation.
Suspension or revocation of the issued EAC certificates
The validity of the issued EAC declaration may be suspended temporarily or permanently in the following cases:
- The authorized representative and the applicant have mutually agreed to revoke the validity of the EAC declaration
- The applicant has decided to end the EAC declaration
- The authority that carries out the state control over the declared products was informed about quality deficiency
The decision on suspending or revoking the conformity certificate is made by the certification body. The applicant will be informed of the decision in writing within five working days.
The rights of the applicant
The applicant has the right to:
- select the forms and schemes of attestation of conformity for the goods specified in the technical regulations,
- to address itself to that certification body whose scope of accreditation applies to the declared goods,
- use the EAC conformity mark,
- to lodge complaints with the authorised body about unlawful acts by the certification bodies and centres (laboratories),
- as well as to apply to the court for the protection of their rights and legal interests.
The duration and costs associated with an EAC declaration application depend on several different factors, such as the classification of the product, any required laboratory checks and the complexity of all examinations. As such the exact conditions of the EAC declaration are always determined individually based on the required documentation.
Please note that an application for an EAC declaration can take anywhere from a few days to weeks to process.