Since 2018 manufacturers became more involved in the certification process because of two reasons.

First of all the certification system in Customs Union countries (Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan - currently called Eurasian Economic Union) is more active and alive than ever. Everything must be made stick to the law. There is no place for requests such as “I need the certificate of conformity tomorrow. Please, no sample, no audit”. The nowadays EAC approval procedure fully reveals the idea of a certain Technical Regulation (TR CU). The manufacturer should come through all procedures usually being lead by the hand by a certification agency.

Secondly, clients desire to be fully informed about the most accurate certification scheme in order to exclude all problems and evaluate all the risks.

So, the interaction increased significantly.
Two years ago anyone even did not hear about certification schemes. But now every day we are receiving questions such as:

“What is the difference between 1d and 3d schemes”.

“What certification body and certification laboratory will be involved in the approval process”

“ Can the manufacturer’s test reports be accepted as evidence”

So, if we will consider the Technical regulation of the Customs Union 020 “Electromagnetic compatibility of technical means” (TR CU 020/2011) or 004 “On the safety of low-voltage equipment” (TR CU 004/2011) as an example, we can note that for serially produced products two main schemes - 1d and 3d - schemes that determine correct procedure for issuing the Declaration of conformity (DoC).
The is one more approval form – the Certificate of Conformity, but here there are no doubts – tests must be made in the accredited laboratory in Russia.

So, let’s go deep in the DoC issues.

According to 1d scheme the DoC for a technical product is carried out on the basis of on-site evidence.

3d scheme assumes that conformity evidence (test reports) must be obtained with the participation of an accredited testing laboratory (center) and/or quality management certification body included in the Customs Union (CU) Common Register of Certification Bodies and Testing Laboratories.

In fact, it means that there are two possible ways for the applicants:

  • If I produce the electronic device and my product needs the Declaration of Conformity to TR CU EMC and/or LVD, I can investigate the legal field of the Customs Union - standards that can be applied to my product. All these standards are mentioned in the Annexes to the technical regulation of the Customs union and usually are followed by a prefix “GOST”. So, the idea is that the manufacturer needs to be confident that the product is in conformity with these standards. It can be done through making researches (tests) in the own laboratory of the manufacturer OR applying for tests in any other laboratory. It is up to the applicant’s decision. He decides the way this conformity will be proved.
  • If I producу the electronic device and my product needs the Declaration of Conformity to TR CU EMC and/or LVD, I can apply to the accredited certification laboratory in CU that can make all necessary tests and issue a test report. In this case, I am applying to the laboratory whose competence was confirmed by the main Accreditation Boby - Rosaccreditacia, so it guarantees the quality of all the procedures (sampling and tests).

Here our idea is facing up with the common practice for previous years that says that there is no possibility to provide foreign test reports according to IEC standard as evidence even while 1d scheme Declaration of Conformity. Just because all certification providers get used to working in this manner (accepting test reports that were done only in CU laboratories). But there is no one word in the TR CU 020 (EMC) or TR CU 004 (LVD) that requires test reports of the CU origin while using 1d scheme.

We are practicing the approach when IEC reports can be also accepted as evidence that products are in conformity with TRs CU. The main reason is that in the List of GOST standards (Annex to TR CU EMC ) there are references to the IEC analogs.

For example, GOST 30886-2002 has a reference to EN 55103-1:1996. The text of this GOST standard mentiones that is identical to EN 55103-1:1996. So, in fact, test reports according to EN 55103-1:1996 will prove that applied products meet all the requirements of TR CU.

In conclusion, we have 3 possible ways of declaring product according to TR CU 020 (EMC) and TR CU 004(LVD): 

  1. 1d scheme with issuing reports in the laboratory located in CU.
  2. 1d scheme with reports issued in manufacturer’s laboratory / or European testing laboratory. 
  3. 3d scheme with reports issued in the accredited certification laboratory located in CU.

Here the link where you can find the list of standards that should be applied while making test and issuing certificates/declarations of conformity to TR CU 020 (EMC) and TR CU 004 (LVD) in comparison with European/International standards (the TR CU 020 list was finalized, TR CU 004 standard list is in process - is to be updated weekly).

WWbridge specialists can consult you on the most suitable way in terms of your exact product.
Just ask us.

Looking forward to hearing from you

By Viktoriia Artemenko 
Head of Certification Department

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