Certification or Declaration Under TR CU 018
Three conformity assessment forms, two of which apply to parts. Where responsibility sits in each, and what decides which one your product takes.
For EAC certification, Russia uses the same certificate or declaration as the rest of the Eurasian Economic Union: issued under the technical regulations, valid in all five member states. Russia changes three things. The applicant must be a legal entity registered in a member state, so for Russia a Russian importer or an authorised representative under contract with you. The document is entered in the register kept by the Federal Service for Accreditation (Rosakkreditatsiya, the FSA), and that entry is what customs reads. And for some products the EAC document is only the first layer: a state registration certificate, a FAC document, a radio frequency conclusion or an encryption notification comes on top.
The applicant named on the certificate or declaration must be a legal entity or individual entrepreneur registered in a member state of the Union. A foreign manufacturer cannot apply alone. For Russia, one of three parties qualifies: your Russian importer, your own Russian subsidiary, or an authorised representative under contract with you, carrying the applicant's obligations for the product on the market.
EEC Council Decision No. 41 of 20 March 2018 fixes the same rule for declarations. Whoever signs, holds. A serial certificate in the name of your distributor runs for up to five years, and for those five years the distributor decides who else may rely on it; when the relationship ends, the certificate does not move with you. Where a manufacturer plans to sell through more than one importer, we place the applicant role with a party that does not compete for the territory.
The hold that recurs at Russian customs is a mismatch: the importer on the customs declaration is not the applicant on the EAC declaration and cannot show a contract or an authorisation linking the two. The document is genuine, and the consignment waits while the paperwork is assembled. Settle the applicant before the first purchase order names the consignee.
The applicant may sit in any member state, and the document is valid in all five. Raising the document through an applicant in Kazakhstan or Belarus gives the same Union-wide entry; the question of who holds it deserves the same care.
Russia's accreditation body is the Federal Service for Accreditation, Rosakkreditatsiya, shortened to the FSA. It accredits the certification bodies and testing laboratories, keeps the Russian part of the Union's Single Register of Certification Bodies and Testing Laboratories, and keeps the register in which every EAC certificate and every EAC declaration is entered. Customs officers and surveillance inspectors read that register; the paper in your file is a printout of it.
Under Article 54 of the Treaty on the Eurasian Economic Union of 29 May 2014 the member states recognise each other's accreditation, and a certification body applies to the accreditation body of the state where it is registered as a legal entity. Inclusion in the Single Register follows the procedure of Customs Union Commission Decision No. 319 of 18 June 2010. A body accredited in Russia is listed by the FSA and recognised in the other four states.
Bodies lose accreditation. When one does, the certificates and declarations it registered come into question with it, and a product that cleared customs for two years can be stopped on the next consignment. So the body's status must be checked in the FSA register at the time of filing, and the laboratory's scope must cover the regulation's test methods. We check both before the samples ship and again before issue, because a status can change between the two.
For most machinery and electrical goods, nothing: the EAC document, the EAC mark and labelling in Russian are the whole requirement. For a defined set of products Russia asks for a second document from a second authority, and the EAC document replaces none of them. The set is short and follows the customs code, so confirm it before the samples go to the laboratory.
Two of the layers are Union-wide. The state registration certificate (SGR) is issued by Rospotrebnadzor for specialised food, a named subset of cosmetics, chemicals and food-contact materials, and it has no expiry date. The encryption notification is registered with the FSB and entered in the Union register, and it catches any device with Wi-Fi, Bluetooth or a TLS client. Two are Russia only: the FAC document for equipment attached to a public communications network, and the radio frequency conclusion that customs asks for on anything that transmits. Cryptography outside the notification categories takes an import licence from the Ministry of Industry and Trade, also Russia only.
Separate authorities issue these, in parallel. The applicant can differ too: the encryption notification is registered against the manufacturer and published, while the FAC document and the frequency conclusion are held by a party established in the Union. The mistake we see is a manufacturer who budgets the EAC declaration for a Wi-Fi controller and meets the other three at the border. The label and the operating instructions must be in Russian, and the EAC mark goes on once the document exists, applied by you or the importer.
Three to eight weeks for a typical product, the same range as the rest of the Union, because the steps match: regulation analysis, scheme, samples, tests, inspection where the scheme has one, issue and entry in the FSA register. A serial certificate runs up to five years with an annual inspection; a single-batch certificate covers one consignment and skips the inspection.
Three things stop the clock, and none of them is the laboratory. The applicant has not been appointed, so a finished certificate cannot be signed. The technical file exists only in English, and the Russian label and instructions are still in draft when the body could issue. Or the customs code was guessed, and the product turns out to trigger a state registration or a FAC document that nobody priced. Appoint the applicant on day one, send the Russian label artwork with the samples, and confirm the customs code before the laboratory is booked.
| Document | Issued or registered by | Valid where |
|---|---|---|
| EAC certificate of conformity | Certification body accredited by the FSA and listed in the Single Register | Whole EAEU |
| EAC declaration of conformity | Signed by the applicant, entered in the FSA register under EEC Council Decision No. 41 | Whole EAEU |
| State registration certificate (SGR) | Rospotrebnadzor | Whole EAEU |
| Encryption notification | FSB, entered in the EEC unified register | Whole EAEU |
| FAC certificate or declaration | Communications certification system overseen by Roskomnadzor | Russia only |
| Radio frequency (RFC) conclusion | GRChTs, the radio frequency authority | Russia only |
The first four rows are recognised in all five member states whichever state the applicant sits in. The last two exist only in Russia, and an import licence for cryptography outside the notification categories, from the Ministry of Industry and Trade, is Russia only as well.
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No. The certificate is issued under a technical regulation of the Union and is valid in all five member states whichever state the applicant sits in. What differs is the national side: which accreditation body listed the certification body, which register holds the entry, and which extra documents the destination asks for. For Russia those are the FSA register and, for some products, the SGR, FAC, RFC and encryption layers.
Yes, and it is the quickest arrangement on day one. The distributor becomes the holder of a document that can run for five years, and only the holder can amend it or authorise another importer to rely on it. If the relationship ends, the document stays with them and you start again. Where more than one importer is planned, an authorised representative that does not sell in the territory keeps the document yours.
The documents it issued or registered come into question with it, and the next consignment can be stopped at customs on a certificate that cleared the previous one. The body's status in the FSA register has to be checked at the time of filing, and again before a large shipment. If the body is gone, the workable route is a new document from a body that is listed.
For most machinery and electrical goods, no: an EAC declaration Russia's customs can find in the FSA register, the EAC mark and a Russian label are enough. Specialised food, a subset of cosmetics and chemicals add a state registration certificate. Anything that transmits or attaches to a public network adds the FAC document and the radio frequency conclusion, and anything with Wi-Fi, Bluetooth or TLS adds the encryption notification.
Three conformity assessment forms, two of which apply to parts. Where responsibility sits in each, and what decides which one your product takes.
Scope across categories M, N and O, chassis and safety components; the requirements it sets; and who in the supply chain it binds.
Categories M, N and O, chassis, and safety-related components. Plus what modification triggers, and the three vehicle types excluded outright.
One specialist owns your file from the first email to the registered certificate. Every one of them has recorded a briefing on their field.
Send the product name, HS code and technical data. You get back the applicable route, the document list and a timeline, before any commitment. For Russia, the first reply says who can be the applicant on your document, which register entry customs will read, and which of the SGR, FAC, RFC and encryption layers your product triggers.
Scoping is freeReply within one working day