Explosion protection is a field that follows mostly uniform fundamental principles of explosion safety worldwide. Around the world, various countries and regions have implemented their own standards and certification systems for explosion-proof equipment, some of them are applied globally. In Europe, the ATEX Directive 2014/34/EU applies. ATEX is the European Union directive that regulates the safety of equipment and protective systems intended for use in explosive atmospheres. IECEx is a global certification system which is not legally mandatory, but it is recognized in the EU. It was officially adopted by Australia, New Zealand, Singapore, India, and Israel. In the US, equipment must comply with NEC classification, meet OSHA workplace safety rules, and be certified by recognized labs like UL or FM to be legally used in hazardous locations. The countries of the Euarisan Economic Union (Kazakhstan, Russia, Belarus, Armenia, and Kyrgyzstan) have elaborated their own regulation, which provides the safety requirements for electrical and non-electrical equipment operated in potentially explosive surroundings for the protection of life, health, property and the environment - TR CU 012/2011 "On the Safety of Equipment for Operation in Explosive Atmospheres"
That is why, in international projects, it is crucial to ensure full compliance with all regulations governing explosion-proof equipment. In this article, we take a closer look at the differences between the ATEX Directive and TR CU 012/2011.Although the two technical regulations have many overlaps and remarkable similarities (some wording is identical), there are also clear differences, such as:
- TR CU 012 recognizes a third level of protection for mining: PO, PB, PП
- There is no equivalent to “Internal Production Control” in TR CU 012
- The Technical Regulation TR CU 012/2011 does not provide for a manufacturer’s declaration (EAC Declaration) as in the ATEX Directive 2014/34/EU (Module A – Internal Production Control)
In the table, we have summarized the key features of ATEX, TR CU 012/2011 and IECEx:
| Feature | ATEX (EU) | TR CU 012/2011 (EAEU) | IECEx |
|---|---|---|---|
| Legal area | European Union, obligatory | Eurasian Economic Union (RUssia, Kazakhstan, Belarus, Armenia, Kyrgyzstan), obligatory | Global (any country that recognizes IECEx), voluntary |
| Legal source | Directive 2014/34/EU | Technical Regulation TR CU 012/2011 | IECEx standards |
| Application area | Electrical and non-electrical equipment in explosive atmospheres | Electrical and non-electrical equipment and Ex-components | Electrical and non-electrical equipment and Ex-components |
| Conformity assessment procedure | Manufacturer declaration for Category 3, Notified Body for others | Certificate only via accredited EAC body | Certificate only via accredited IECex body |
| Schemes / Modules | Modules A, B, D, F, C1, E, G depending on equipment category | Schemes 1c, 3c and 4c depending on delivery type – series, single, batch | Single standardized process (product testing and factory audit) |
| Marking | CE + Ex  |
EAC Ex  |
- |
| Zones / Categories | Zone: Gas: 0, 1, 2; Dust: 20, 21, 22; Group: I, II; Category: 1, 2, 3 | Zone: Gas: 0, 1, 2; Dust: 20, 21, 22; Group: I, II, III; Group I: PO, PB, ПП; Group II: 0, 1, 2 |
Zone: Gas: 0, 1, 2; Dust: 20, 21, 22; explosion protection a, b, c |
| Quality system audit | QAN/QAR required for category 1 and 2 | Quality system audit required under scheme 1c | Quality system audit required |
| Language of documentation | Local EU languages | Russian and local EAEU language | English |
| Applicant | Manufacturer or EU authorized representative | Only legal entity within EAEU, manufacturer’s representative | Manufacturer or his authorized representative |
| Testing body | Notified Bodies | Accredited EAC certification bodies | Accredited IECEx certification bodies |
Does the device need to already have an ATEX or IECEx certificate to obtain an EAC Ex certificate?
No, an ATEX certificate or other approvals for explosion-proof equipment are not a prerequisite for obtaining a certificate under the TR CU 012/2011 regulation. The certification body independently assesses the safety of the device regardless of existing approvals. However, having an ATEX certificate can simplify the EAC certification process.
It is also important to understand that ATEX or IECEx certificates are not recognized as proof of explosion safety within the Eurasian Economic Union (EAEU). To sell and operate explosion-proof equipment in the EAEU, an EAC certificate according to TR CU 012/2011 must be issued.
Are the test reports or audits from ATEX certification recognized?
No, EAC certification is an independent process. The ATEX certificate and test reports can be helpful references, but they cannot replace the audit or product testing carried out by an accredited certification body. The technical regulation TR CU 012/2011 requires that product samples be tested by a laboratory approved within the EAEU. The same applies to on-site inspections and the audit of the quality management system for serial production (Scheme 1c).
Can the EAC Ex certificate be replaced by an EAC EX declaration?
No. The technical regulation TR CU 012/2011 does not provide for a manufacturer’s declaration (EAC Declaration). Unlike the European system under the ATEX Directive 2014/34/EU, where the manufacturer may declare conformity independently for certain categories of equipment (e.g., Module A – Internal Production Control), the EAEU regulation requires certification exclusively by an accredited certification body within the EAEU. This means that the manufacturer or its authorized representative in the Eurasian Economic Union (EAEU) must submit an application to a certification body accredited in one of the member states. The certification body will then review the technical documentation, product samples, and quality management system.
An independent “manufacturer’s declaration” or self-certification—as allowed under ATEX for certain product categories—is therefore not permitted within the EAEU system.
Can explosion-proof equipment with an EAC Ex certificate also be installed in safe areas?
Yes. It is only necessary to check whether other regulations might also apply. For example, an existing Ex certificate cannot replace the requirements of TR CU 004 on the safety of low-voltage equipment.
It is also important to note that as soon as the equipment carries an Ex marking, it must have the Ex certificate, even if it is used in safe areas.
Who is responsible for compliance with regulations in the EAWU?
Similar to ATEX certification, either the manufacturer (if it is a domestic manufacturer) or the authorized representative is responsible for ensuring that the regulations are followed. A manufacturer not established in one of the Eurasian Economic Union member states is not entitled to apply for a conformity assessment of its products for compliance with the relevant technical regulations.
To conduct a conformity assessment, a foreign manufacturer must appoint an authorized representative in one of the EAWU member states. This representative acts on behalf of the foreign manufacturer in cooperation with EAWU certification bodies regarding product safety, quality, and compliance with technical regulations.
According to applicable law and the technical regulations of the Union, only an entrepreneur residing within the territory of the Eurasian Economic Union may be appointed as an authorized representative.
Schmidt & Schmidt supports manufacturers from Europe, America, and Asia in appointing an authorized representative in the EAWU. Thanks to our legally compliant solution concept via Kazakhstan – an EAWU member state – we can ensure the issuance of EAC certificates . With our local offices, we ensure that the entire certification process complies not only with the technical regulations of the Eurasian Economic Union but also with European and American sanction rules, providing our clients with a reliable and legal access to the EAWU market.
Can the EAC EX Certificate be extended?
The TR CU regulations do not provide for an extension of the certificate. After its expiration (usually after 5 years), the certificate is archived in the registry. If the product continues to be sold, a new certification must be applied for. The entire certification process must be repeated.
Can the EAC EX Certificate be revoked?
Yes. The EAC EX Certificate can be suspended or revoked in accordance with the Technical Regulation TR CU 012/2011 “On the Safety of Equipment for Use in Explosive Atmospheres” and the accreditation rules of the Eurasian Economic Union (EAWU).
The suspension or revocation is carried out by the accredited certification body and recorded in the unified EAWU registry.
The certificate status will be updated as follows:
- Suspended
- Cancelled
After revocation, the “EAC EX” marking may no longer be used on the product or in accompanying documentation.
Reasons for Revocation or Suspension
- Non-conformity of products: The product does not match the tested sample or has been modified without notifying the certification body.
- Missing or incomplete technical documentation: e.g., missing safety justification (Обоснование безопасности), operating manual (РЭ), or test reports.
- Errors or manipulation: Irregularities in test reports, documents, or EAC markings.
- Failure to pass inspection control: For serial production, annual inspection is required. Failure to conduct it leads to temporary suspension and eventual revocation of the certificate.
- Termination of the certification body’s activities: Loss or revocation of accreditation.
- Voluntary withdrawal: The applicant (manufacturer or authorized representative) can request revocation.
Restoration of the Certificate
A suspended certificate can be reactivated if the manufacturer remedies the identified deficiencies and provides evidence or undergoes a new audit. A cancelled certificate cannot be reactivated.
How should the marking on explosion-proof equipment look?
In addition to the EAC mark, the Ex mark must also be applied. The equipment must be labeled with a specific EX symbol.
The EAC EX marking consists of a combination of two stylized letters “E” and “x.” Ex stands for explosion protection. The height of the “x” is 5/9 of the height of the “E.” The mark must be placed on a white or contrasting background.
The dimensions of the EX mark must ensure readability with the naked eye on the background, with a minimum height of 10 mm. The height-to-width ratio is 11/8.
The Ex mark should be applied to every device, Ex component, or corresponding documentation.
