TR CU 017 Layers: Which Approval Your Garment Needs

Which two approvals does TR CU 017 offer?

TR CU 017, On the safety of light industry products, provides for:

• A Certificate of Conformity (CoC)
• A Declaration of Conformity (DoC)

Which applies is not a choice. It follows from the product layer, and the layer is defined by the intended use of the product and its area of contact with the human body.

What are the three layers?

First layer

Products in direct contact with human skin: underwear including swimwear, bed linen, corsetry, bathing products, summer headwear, hosiery, handkerchiefs, shawls and scarves, T-shirts, tops.

Second layer

Limited contact: dresses, blouses, shirts, trousers, skirts, suits and jackets without lining, sweaters, jumpers, pullovers, headwear other than summer, mittens, gloves, winter hosiery.

Third layer

Clothing worn over second-layer items: coats, short coats, jackets and suits with a lining, raincoats.

Once the layer is settled, the practical work is sample preparation, see preparing clothing for laboratory testing and sending clothing samples for EAC testing.

Where the classification is easy to get wrong

The lining is doing real work in this scheme. An unlined jacket is second layer; the same jacket with a lining is third. Both declare, so the consequence there is small, but the principle matters at the first-to-second boundary, where the document changes.

A T-shirt is first layer and needs a certificate. A shirt is second layer and needs a declaration. The difference in process, cost and lead time between those two documents is substantial, and it turns on which garment the product actually is under the regulation rather than what a catalogue calls it.

Sources

• TR CU 017/2011, On the safety of light industry products, Eurasian Economic Commission
• TR CU 007/2011, On the safety of products intended for children and adolescents, for products under 18