EAC certification Kazakhstan: one Union document, a Kazakh applicant

No. The technical regulations are Union law, so TR CU 004/2011 on low-voltage equipment, TR CU 020/2011 on electromagnetic compatibility and TR CU 010/2011 on machinery read the same in Almaty as in Minsk, and the schemes of EEC Council Decision No. 44 of 18 April 2018 are the same too. An EAC certificate for Kazakhstan is accepted by a customs officer in any other member state. What is national is who accredits the body, which part of the register holds the entry, and who inspects the market afterwards. The general rules are on EAC for the Eurasian Economic Union; the Belarusian details sit on EAC Belarus.

Accreditation is national by design. Under Article 54 of the Treaty on the EAEU of 29 May 2014 the member states recognise each other's accreditation, and a certification body or testing laboratory applies to the accreditation body of the state in which it is registered as a legal entity. So a Kazakh body is accredited in Kazakhstan, listed in the Kazakh national part of the Single Register of Certification Bodies and Testing Laboratories under Customs Union Commission Decision No. 319 of 18 June 2010, and its certificates count across the Union. Market surveillance stays national as well: for Kazakhstan the EEC lists the Ministry of Trade and Integration of the Republic of Kazakhstan as the authorised body.

Before we contract a Kazakh body we read its register entry, because accreditation is a list of regulations and product codes and nothing else. A certificate issued for a product outside that list looks like every other certificate. It fails months later, when someone in another member state checks the number against the register and finds the body had no right to issue it. We do that check before we quote.

A legal entity or individual entrepreneur registered in Kazakhstan. Either your Kazakh importer, or an authorised representative that the manufacturer appoints under contract. EEC Council Decision No. 41 of 20 March 2018 applies the same rule to declarations. The applicant is named on the document, holds it, and answers to the surveillance authority if a batch fails.

Manufacturers increasingly route the whole Union through a Kazakh applicant because the document is Union-wide, so the state whose body issues it can be the state where the manufacturer already has a contract partner. One certificate, held by one Kazakh entity, then serves shipments to the rest of the Union as well. Where several importers are planned, an applicant that is not one of them keeps the certificate out of any single distributor's hands.

The hold we see most often is in another member state. A certificate names the Kazakh applicant; the consignment enters another member state with a local importer on the customs declaration; the officer sees a document held by a company that is not the declarant. The certificate is valid, and the shipment still waits for a letter from the holder confirming that this importer ships under it. We prepare that letter with the certificate, before the first truck leaves, because the second time it is requested is at the border.

The regulation decides, per product category, whether you take a certificate from an accredited body or an EAC declaration Kazakhstan registers in the national part of the register. A declaration is signed by the applicant on its own responsibility. Under Decision No. 44, scheme 1d rests on your own evidence and scheme 3d on tests in an accredited laboratory, and Decision No. 41 fixes what the applicant must hold before it signs. Most declared products need a laboratory report behind the signature.

A declaration registered without the tests its scheme requires is void the day someone checks it. The offer that skips the laboratory saves exactly the price of the tests, and what you buy is a registration number with nothing under it. Surveillance in Kazakhstan sits with the Ministry of Trade and Integration, and an inspector in any other member state reads the same register. Ask any body quoting for a declaration which laboratory will test and which scheme it will print.

A few product groups have no EAEU technical regulation yet and are governed by national standards of Kazakhstan instead. For those the document is national and does not travel to the other four states. We check the product against the regulation list before anyone orders a test, because a test against a Union regulation that does not cover the product is a report you cannot use anywhere.

The same file as anywhere in the Union: a technical description, the manufacturer's documents, samples for the laboratory, the contract that makes the Kazakh entity the applicant, and the manual and technical passport in Russian. Three to eight weeks for a typical product; a scheme with a factory inspection, 1c above all, runs longer, and the applicant contract has to exist before the certificate can be issued, so it is signed first.

The EAC mark is the same mark and is applied by the manufacturer or the importer once the document exists. What the label and the manual must say beyond the mark is fixed by each regulation, and the Kazakh body will read the Russian manual against the regulation before it issues anything. A manual delivered in English only stops the file on the reviewer's desk. Send the Russian version with the samples.