EAEU RoHS: TR CU 037 Schemes and Lead Times

What does TR CU 037 restrict?

TR CU 037, On restriction of the use of hazardous substances in electrical and radioelectronic products, has applied since 1 March 2020. It restricts six materials:

• Lead
• Cadmium
• Mercury
• Hexavalent chromium
• Polybrominated biphenyl
• Polybrominated diphenyl ether

The approval document is a Declaration of Conformity, not a certificate, so there is no audit and no mandatory sampling.

Like other Customs Union documents it is valid across all five member states of the Union. Validity can be 1, 3 or 5 years, or a batch declaration covering a single delivery.

For the product categories the regulation reaches, see which products TR EAEU 037 covers.

Which schemes are available?

How does scheme 1d work?

1. Reports from a qualified voluntary laboratory. Lead time: about one week once all required documents are submitted.

2. European or manufacturer’s test reports issued to RoHS Directive 2002/95/EC. All reports must be submitted in the Union’s working language, so translation is part of the schedule. Lead time: about one week once translated reports are in.

3. Reports for the product parts that are subject to RoHS. Only available if the manufacturer can supply both a RoHS risk assessment and RoHS test reports for every part in scope. Lead time depends on the number of components and the volume of documents to evaluate.

Route 2 is the one that surprises manufacturers pleasantly. The substance list matches the European directive, so a company already selling into the EU usually holds most of what it needs, and the remaining work is translation rather than testing.

Route 3 is the opposite: it looks like a shortcut for a complex assembly and is often the slowest, because it multiplies the evidence to be assembled and reviewed.

Scheme 3d: local testing

The manufacturer provides samples for testing at an accredited laboratory inside the Union, which issues the declaration to TR CU 037 on positive results.

Lead time starts from one week once the required documents are submitted, the draft declaration is confirmed and the laboratory has received the samples. It can extend depending on the product type, the testing schedule the product needs, and the laboratory’s workload, so treat one week as a floor and not as an estimate.

Sources

• TR EAEU 037/2016, On restriction of the use of hazardous substances in electrical and electronic products, Eurasian Economic Commission
• Directive 2002/95/EC (RoHS), European Union, for the equivalence of substance limits