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Russian RoHS comes into effect since March 1, 2020

Russian RoHS comes into effect since March 1, 2020


Posted on Feb 03 Legal Tips, Russian Market

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RoHS as a mandatory requirement for the imported products to the territory of Customs Union countries will be implemented since spring 2020. You want to export to the CU and your products are your products are subject to RoHS Directive? Study this article to be aware of all the details related to the topic.



New Technical Regulation of Customs Union – TR CU 037 «On Restriction of the Use of Hazardous Substances in Electrical and Radioelectronic Products» (RoHS) should be complied with starting from March 1, 2020.

RoHS sets restriction requirements for use of the following hazardous materials in electrical and electronic products:
  • Lead;
  • Cadmium; 
  • Mercury;
  • Hexavalent chrome; 
  • Polybrominated biphenyl;
  • Polybrominated diphenyl ether.

Approval document should be issued in form of Declaration of Conformity (DoC).

Along with other Technical Regulations of the CU, DoC for RoHS is valid within 5 member-states of Customs Union – Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan.

Manufacturer can apply for 1, 3, 5 years validity or get RoHS Declaration for batch (single delivery).

There are 2 schemes according to which the manufacturer could get approval document for Russian RoHS:

- 1D scheme – based on test reports
- 3D scheme – with local testing in Russia

1D scheme

Several options are applicable within this scheme:

1) Based on test reports from a qualified voluntary laboratory

Lead time – 1 week once all required documents are submitted

2) Based on European/manufacturer’s test reports issued according to RoHS Directive 2002/95/EC

Please note that all the test reports should be submitted in Russian. WorldWideBridge can assist you with translation if required.
Lead time – 1 week once translated test reports are submitted.

3) Based on test reports for product parts that are subject to RoHS

Be informed that this scheme is applicable only if the manufacturer is able to provide RoHS risk assessment and RoHs test reports for all parts that are subject to RoHS.
Lead time depends on number of components and number of documents provided for evaluation.

3D scheme

According to the scheme, the manufacturer is obliged to provide samples for local testing to the Russian accredited laboratory which will issue the DoC to TR CU 037 in case of positive test results of the declared products.

Lead time – starts from 1 week once all required documents are submitted, DoC draft is confirmed and samples for testing are received by the laboratory. Please be informed that the lead time could be prolonged depending on the product type, required timing schedule for its testing and workload of the laboratory.

General list of documents required for TR CU 037 «On Restriction of the Use of Hazardous Substances in Electrical and Radioelectronic Products»:

• Applicant agreement between the applicant (local representative) and the manufacturer
• Applicant's legal documents (taxpayer ID number, primary state registration number etc.)
• User manual in Russian
• Test reports

Please note that only local representative of the CU countries can apply for getting Russian RoHS. WorldWideBridge can assist you and act as an applicant.

If you have an inquiry, please contact our team. We are always pleased to provide good service and consulting for our clients!

By Evgenia Kovaka
Key Account Manager





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