Summary: Selection, Sampling, and Dispatch of Test Samples

Mandatory Customs Procedure under Decision No. 130: Test samples for EAC conformity assessment must never be imported as standard postal parcels ("samples of no commercial value") or in passenger hand luggage. Customs clearance under an official customs declaration (DT) utilizing the dedicated customs procedure code 061 ("goods imported as samples and specimens for research and testing") is legally mandatory.
The Critical Risk of Simplified Postal Declarations: Following the comprehensive digitalization of state registers, the DT registration number is electronically matched with customs databases upon certificate issuance. If an official customs declaration under code 061 is missing, the registry software automatically blocks the entry of the test report, or the certificate is declared null and void during regulatory post-clearance audits.
Sampling Protocol under GOST 58972-2020: Sample selection follows rigorous regulatory standards. For EAC Certification (Scheme 1c), sampling must be executed directly at the manufacturing plant by accredited assessors and documented in an official Sampling Act (*Akt otbora prob*); for EAC Declarations, the manufacturer selects representative specimens under its own responsibility.
Strict Prohibition of Markings Prior to Approval: Prior to the formal completion of conformity assessment, test samples must not bear an EAC Mark. Affixing the conformity mark before certificate issuance is classified by customs authorities as an act of consumer deception and will result in immediate customs seizure.
Conditional Release (Art. 126 EAEU Customs Code): For large, non-divisible industrial machinery, goods may be imported under customs supervision and assembled directly at the recipient's bonded premises prior to testing. The importer is granted a strict statutory deadline of 45 days to complete on-site testing and submit the final EAC Certificate to customs.
Sanctions-Compliant Logistics via Kazakhstan: As test sample shipments directly to Russia or Belarus are blocked by Western trade embargoes (Regulation (EU) No 833/2014, Annexes VII and XXIII) and carrier suspensions, Schmidt & Schmidt routes sample logistics directly to accredited testing centers in Kazakhstan—fully transport-secure and compliant with international sanctions.

Why Legally Compliant Sample Import Determines Certification Success

Importing product samples for conformity assessment within the Eurasian Economic Union (Russia, Belarus, Kazakhstan, Armenia, Kyrgyzstan) involves a tightly interconnected framework of customs law and technical regulation.

In past years, manufacturers frequently dispatched test specimens via standard courier express with proforma invoices under 200 Euros declaring "samples of no commercial value." In the current regulatory environment, this practice inevitably leads to project failure: state supervisory agencies (such as Rosakkreditatsiya in Russia or the NCA in Kazakhstan) have synchronized their digital platforms directly with state customs clearance databases.

Consequences for International Exporters: When uploading the test report into the centralized state registry, the system mandates the entry of the official customs declaration number (DT) for the tested samples. If this customs record cannot be verified, the certification body is legally barred from issuing the registration—or the certificate will be revoked retroactively during post-clearance customs audits, leading to administrative fines and immediate border blockades.

Sample Shipment for EAC Certification and Declaration

Statutory Framework: EEC Decision No. 130 and Procedure Code 061

The statutory basis for sample importation is established by EEC Board Decision No. 130 ("On the Regulation on the Procedure for Importing Products...") in conjunction with Customs Union Commission Decision No. 378:

Customs Procedure Code 061: In Box 37 of the customs declaration (DT), the declarant must explicitly state procedure code 061 ("goods imported as samples and specimens for research and testing"). Box 31 must include the mandatory notation: "Samples for the purpose of confirming compliance with TR CU/TR EAEU technical regulations".
Mandatory Tripartite Documentation: The customs entry dossier must include:
- The formal contract between the foreign manufacturer (or its Authorized Representative) and the accredited certification body or testing laboratory;
- An official notification letter issued by the certification body confirming the exact sample quantities (unit count, weight, dimensions) strictly required for the test program;
- A proforma invoice containing explicit model codes, part numbers, and serial designations matching the technical dossier.

Warning Regarding Simplified Postal Clearance: While customs legislation provides simplified procedures for low-value mail shipments below certain thresholds, these mechanisms do not generate a full DT customs declaration with procedure code 061. Because official EAEU registries require a verified DT number for serial certification, we strongly advise international manufacturers against sending unescorted test samples via standard postal channels.

Sample Selection and Sampling Protocols (Sampling under GOST 58972-2020)

Sampling procedures are governed by the intergovernmental standard GOST 58972-2020 ("Conformity assessment. General rules for sampling for product testing"). This standard ensures that selected units are fully representative of ongoing serial manufacturing:

Procedural Parameter	EAC Certification (e.g., Scheme 1c, 2c)	EAC Declaration (e.g., Scheme 3d, 6d)
Who conducts sampling?	An accredited assessor from the certification body or an authorized inspection body on-site at the factory.	The manufacturer independently or its appointed authorized representative in agreement with the laboratory.
Sampling Location	Finished goods warehouse at the manufacturing facility or a bonded customs warehouse prior to final clearance.	The manufacturer's plant, distribution warehouse, or finished goods inventory.
Mandatory Document	Official *Sampling Act (Akt otbora prob)*, signed by the auditor and plant director, stamped with the factory seal.	Internal manufacturer sample dispatch sheet documenting batch numbers, manufacturing dates, and origin.
Verification of Representativeness	Randomized selection from a completed, quality-cleared commercial batch; samples must be identical to serial production.	Selection of a worst-case representative model in accordance with the technical specifications.

Sample Quantities, the Worst-Case Principle, and Testing Groups

Determining the required sample quantity depends on the test methods applied (destructive vs. non-destructive testing) and the prescriptions of the applicable Technical Regulations.

The accredited certification body issues an official sampling quantity notification to the manufacturer. Typical industry benchmarks include:

Industrial Machinery and Equipment (TR CU 010/2011): Typically 1 unit per representative product line (testing is generally non-destructive);
Low-Voltage and EMC Equipment (TR CU 004/2011 / TR CU 020/2011): 1 to 2 units (allowing parallel testing for electrical safety and electromagnetic compatibility);
Textiles and Apparel (TR CU 017/2011): 3 to 5 units per material composition (destructive testing for tensile strength, colorfastness, and hazardous chemical content);
Personal Protective Equipment (TR CU 019/2011): Frequently multiple pairs or units, as helmets, fall arrest harnesses, and safety shoes undergo destructive impact and puncture testing.

Cost Optimization through Testing Families: For diverse product portfolios with multiple configurations, our engineering team constructs homogeneous testing groups. We select and test the single model operating under the highest mechanical, electrical, or thermal stress levels (the "worst-case" model). Once it passes laboratory trials, all derived models are included in the certificate appendix without duplicate testing.

Sample Selection Using the Worst-Case Principle

Critical Warning: No EAC Marking on Test Samples!

Labeling Prohibition Prior to Approval: At the time of customs transit and laboratory evaluation, test samples must under no circumstances bear the EAC Mark. EAEU law strictly forbids affixing conformity markings prior to the formal conclusion and registration of the conformity assessment. A test sample carrying a premature EAC logo is treated by customs officers as an act of fraud and is liable to administrative confiscation. The EAC mark may only be affixed to serial products after the certificate is legally registered.

Conditional Release of Industrial Equipment (Art. 126 EAEU Customs Code)

For heavy industrial machinery, large power transformers, or pressure vessels that cannot be evaluated within a testing laboratory, EAEU customs law provides the statutory mechanism of Conditional Release (*Uslovny vypusk*).

Pursuant to Article 126 of the EAEU Customs Code and national implementing statutes (such as Russian Federal Law No. 289-FZ), customs authorities may authorize the release of goods before conformity certificates are finalized:

Purpose-Bound Transit: The machinery is transported under customs bond directly to the final installation site (e.g., the customer's manufacturing plant or a bonded facility);
Use Restriction: Pending certificate issuance, the machinery may be physically erected and installed, but must not be put into commercial operation or transferred to third parties;
45-Day Statutory Window: The importer is granted a strict statutory window of up to 45 days to host accredited experts for on-site witness testing, execute mandatory trials, and submit the final EAC Certificate to customs;
Release into Free Circulation: Only upon electronic verification of the submitted certificate does customs grant final, unconditional release into free circulation.

Conditional Release of Industrial Equipment under Art. 126

Sanctions Compliance & Secure Sample Dispatch via Kazakhstan

Under international sanctions frameworks (EU Regulation (EU) No 833/2014 and Swiss SECO export controls), dispatching commercial prototypes or engineering samples directly to Russia or Belarus creates severe regulatory and legal liabilities for corporate executives.

Primary Trade and Operational Hurdles:

Dual-Use & Goods Embargoes: Numerous industrial machines, valves, electrical modules, and advanced polymers fall under strict export bans (Annexes VII and XXIII); shipping functional samples to Russian test institutes constitutes an export violation;
Sanctioned Test Centers: Multiple state-run testing bodies in Russia appear on international sanctions lists, resulting in financial transaction blocks by Western banks;
Logistics Bottlenecks: Major international freight and express delivery services (DHL, FedEx, UPS) have suspended operations to Russia; test shipments routed across EU external land borders face systematic interception and seizure.

The Legally Secure Route via Schmidt & Schmidt in Kazakhstan:
As a founding EAEU member state, Kazakhstan operates a fully harmonized, internationally recognized accreditation infrastructure:

Test samples from Western manufacturers are routed directly to our regional offices or accredited partner laboratories in Almaty or Astana—completely compliant with export control regulations and shipped via routine air freight;
Testing is executed according to identical intergovernmental GOST standards; the generated test reports and resulting EAC certificates possess full legal validity across all EAEU member states;
All commercial contracts and service billings are handled in Euros through our German corporate headquarters in Passau;
Operating as an independent Authorized Representative, we ensure your ownership rights over test reports and technical files remain entirely independent of local distributors.

For detailed background analysis, consult our briefing: EAC Certification in the Context of International Sanctions.