EAC Approval for Pumping Equipment: Which Form Applies

Certificate or declaration?

Conformity assessment for pumping equipment runs under TR CU 010/2011, On the safety of machinery and equipment. The main technical characteristics and the application decide the form.

The regulation permits replacing a declaration with a certificate. It does not permit the reverse. If a buyer’s tender asks for a certificate on a product that only needs a declaration, that request can be met.

Which regulations stack on top?

• TR CU 004/2011, low-voltage equipment. Applies to electric pumps.
• TR CU 020/2011, electromagnetic compatibility. Also applies to electric pumps.
• TR CU 012/2011, explosion-proof equipment. If the pump is Ex, a certificate here is mandatory, and it is the only possible form.
• State registration, pumps used in drinking-water supply systems are registered with the competent national authority, and the document issued is the SRC, the state registration certificate.

Which pumps are subject to mandatory approval?

Circulation, drainage, downhole, dosing, vacuum, rotary, booster and submersible pumps, among others. The list is not the deciding factor, the technical characteristics and the application are, but if a pump type appears here, assume approval is required and work backwards to the form.

How long is it valid?

Up to 5 years for both the certificate and the declaration, depending on the confirmation scheme chosen. The basis in either case is the test report: results from samples tested in an accredited laboratory against the established list of parameters.

What goes in the document package?

• Approved application form
• Registration and constituent documents of the applicant
• Regulatory and technical documentation for the product, for locally manufactured products
• The authorised representative contract, for imported production
• Technical and operational documentation
• The safety justification, required for a certificate

Standards behind the assessment

Case study: an Italian Ex pump manufacturer

The situation. The client made explosion-proof pumps, supplied with explosion-proof motors bought from third parties. The usual practice when issuing a TR CU 012 certificate for this kind of product is to name both the pump and the Ex components in the certificate, down to specific models. That freezes the bill of materials for the certificate’s five-year life: every shipment has to use exactly those components.

What we proposed. Exclude the motors from the TR CU certificate, and instead confirm with the motor suppliers that they hold valid TR CU certificates of their own. Each shipment to Customs Union countries then has to be accompanied by valid certificates for every component, because at customs clearance, a missing component certificate stops the pumps themselves.

Why it paid off twice. The pumps carry non-electrical Ex marking; the motors carry electrical Ex marking. Non-electrical explosion-proof products can often be tested at the manufacturer’s premises, whereas electrical ones must be tested in an accredited laboratory inside the Union. With the motors already certified by their suppliers, the pumps could be field-tested in Italy.

The client avoided:

• Sending samples
• Customs clearance of those samples
• Customs payments on them

How it ran. WWBridge arranged for two representatives of the certification body to travel to the manufacturer’s site: a testing engineer and an expert to assess the quality management system in production. They carried out the testing and the QMS assessment and issued the reports, and the project closed with the client able to continue exporting.

Two things to watch on Ex pump projects

Ignition risk assessment for non-electrical equipment. This is the part most often underestimated on pump files, and it is not optional.

The operating manual against TR CU 012. Manuals written for another market rarely contain what the regulation expects. Getting the sections right before submission, rather than reworking after a finding, is the cheapest correction available on this kind of project.

Sources

• TR CU 010/2011, On the safety of machinery and equipment, Eurasian Economic Commission
• TR CU 012/2011, On the safety of equipment for work in explosive atmospheres
• TR CU 004/2011 and TR CU 020/2011
• Competent national authorities, state registration of products