Product Certification & Declaration

Product Certification and Declaration Under TR CU Requirements

TR CU/TR EAEU (Technical Regulations of the Customs Union/Eurasian Economic Union) are mandatory normative documents establishing safety requirements for products circulating in the EAEU market (Russia, Belarus, Kazakhstan, Armenia, Kyrgyzstan).

Prior to market introduction, most manufacturers must undergo a conformity assessment procedure, resulting in the issuance of permit documentation. Legislation strictly governs the requirement for product safety confirmation – marketing products without the relevant documents entails administrative liability.

Key Terminology for Product Certification in EAEU:

• TR CU/TR EAEU: Technical Regulations of the Customs Union/Eurasian Economic Union;
• EAEU: Eurasian Economic Union;
• EEC: Eurasian Economic Commission;
• Manufacturer: A legal entity or an individual entrepreneur (including foreign) that manufactures products or has them designed/manufactured, markets them under its name/trademark, and bears responsibility for TR CU compliance;
• Authorized Representative (AR): A legal entity or an individual entrepreneur registered in an EAEU member state that, under contract with a manufacturer (including foreign), performs conformity assessment and places products on the market, assuming responsibility for TR CU compliance;
• Seller: A legal entity or an individual entrepreneur registered in an EAEU member state who sells products under contracts and is not a manufacturer;
• Importer: A legal entity or an individual entrepreneur registered in an EAEU member state that imports products under foreign trade contract and places them on the market, assuming responsibility for TR CU compliance;
• Accredited Testing Laboratory (Center): A legal entity registered in an EAEU member state, officially recognized and included in the EAEU unified register of conformity assessment bodies;
• Analysis of Production Condition (APC): An element of the standard conformity assessment scheme representing a set of actions performed by a product certification body to determine whether the manufacturer possesses the necessary conditions for ensuring consistent (stable) compliance of products placed on the customs territory of the Union with the requirements of the technical regulation, as confirmed during certification.

Key Aspects of TR CU Compliance:

1. Mandatory Requirements Cover:
   • Safety for life and health of consumers;
   • Environmental safety;
   • Energy efficiency (for certain products);
   • Compliance of labeling with established norms.
2. Examples of Key Technical Regulations:
   • TR CU 007/2011 “On the safety of products intended for children and adolescents”;
   • TR CU 008/2011 “On the safety of toys”;
   • TR CU 020/2011 “Electromagnetic compatibility of technical equipment”;
   • TR CU 021/2011 “On food safety”;
   • TR CU 022/2011 “Food products in terms of their labeling”.
3. Types of Conformity Documents:

3.1 Certificate of Conformity TR CU
Issued by an accredited certification body

Examples of products requiring certification:

• Toys (TR CU 008/2011);
• Pressure equipment (TR CU 032/2013);
• Children’s furniture (TR CU 025/2012).

3.2 Declaration of Conformity TR CU
Prepared and registered by the applicant (manufacturer or importer)

Examples of products requiring declaration:

• Furniture other than children’s (TR CU 025/2012);
• Packaging (TR CU 005/2011);
• Low-voltage equipment that is not included in the special list of TR CU (TR CU 004/2011).

3.3 Certificate of State Registration (SGR)
Issued by Rospotrebnadzor

Examples of products requiring SGR:

• Antibacterial wet wipes for children (TR CU 009/2011);
• Children’s cosmetics and perfumes (ТР ТС 009/2011);
• Baby diet food (ТР ТС 027/2012).

4. Conformity Assessment Procedure Includes:
   • Laboratory testing of samples;
   • Analysis of technical documentation;
   • Production control (for serial production);
   • Inspection control (for certified products).
5. Liability for Non-Compliance:
   • Import and sales prohibition;
   • Confiscation of goods;
   • Administrative fines;
   • Criminal liability in cases where non-compliance causes harm to life, health, or property.
6. Labeling Requirements:
   • Mandatory EAC marking;
   • Language requirements (russian and languages of EAEU member states);
   • Information completeness and accuracy.

Certification Schemes (EEC Council Decision No. 44 of April 18, 2018):

Scheme	Applicant	Application Scope	Required Actions	Confirmation of Compliance
1c	Manufacturer/AR	Serial production	Document review + Lab testing + APC + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
2c	Manufacturer/AR	Serial production (with certified QMS)	Document review + Lab testing + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
3c	Manufacturer/AR or Seller/Importer	Batch of products	Document review + Lab testing	Certificate of Conformity for a batch of products
4c	Manufacturer/AR or Seller/Importer	Single unit, if the research (testing) and measurements for this item are non-destructive	Document review + Lab testing	Certificate of Conformity for a single unit
5c	Manufacturer/AR	Serial production, if difficult or impossible to fully confirm compliance with technical regulations during research (testing) and measurements of finished products	Document review + Product design research + APC + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
6c	Manufacturer/AR	Serial production (with certified QMS), if difficult or impossible to fully confirm compliance with technical regulations during research (testing) and measurements of finished products	Document review + QMS review + Product design research  + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
7c	Manufacturer/AR	Products intended for putting serial products into production, in case of planning to release product modifications	Document review + Product type research + APC + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
8c	Manufacturer/AR	Products intended for putting serial products into production (with certified QMS), in case of planning to release product modifications	Document review + QMS review + Product type research  + Annual inspection	Certificate of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
9c	Manufacturer/AR or Seller/Importer	Single product intended for equipping enterprises in the customs territory of the EAEU	Document review	Certificate of Conformity for a single unit

Declaration Schemes (EEC Council Decision No. 44 of April 18, 2018):

Scheme	Applicant	Application Scope	Required Actions	Confirmation of Compliance
1d	Manufacturer/AR	Serial production, when declaring conformity based on the applicant’s own evidence	Document review (by applicant) + Lab testing (accredited or own lab) + APC (by applicant)	Declaration of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
2d	Manufacturer/AR or Seller/Importer	Batch or single unit of products, when declaring conformity based on the applicant’s own evidence	Document review (by applicant) + Lab testing (accredited or own lab)	Declaration of Conformity for a batch of products or for a single unit
3d	Manufacturer/AR	Serial production, when declaring conformity based on evidence obtained with the participation of an accredited testing laboratory (center) and the applicant’s own evidence (if any)	Document review (by applicant) + Lab testing (only accredited lab) + APC (by applicant)	Declaration of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
4d	Manufacturer/AR or Seller/Importer	Batch or single unit of products, when declaring conformity based on evidence obtained with the participation of an accredited testing laboratory (center) and the applicant’s own evidence (if any)	Document review (by applicant) + Lab testing (only accredited lab)	Declaration of Conformity for a batch of products or for a single unit
5d	Manufacturer/AR	Products intended for putting serial products into production, in case of planning to release product modifications	Document review (by applicant) + Product type research + APC (by applicant)	Declaration of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations
6d	Manufacturer/AR	Serial production (with certified QMS)	Document and QMS review (by applicant) + Lab testing (only accredited lab) + APC (by applicant)	Declaration of Conformity for products manufactured in series for a period of no more than 5 years, unless otherwise provided by technical regulations

Mandatory conformity assessment is legally required for products included in the lists of EAEU technical regulations. Marketing such products without proper documentation is prohibited.

Voluntary confirmation of compliance with TR CU/TR EAEU requirements is not provided for – the procedure is either mandatory or not applicable.

EAC marking must be affixed to products that have passed conformity assessment.

Estimated Timelines for Product Certification (TR CU):

The timelines for product certification and declaration under TR CU requirements depend on the type of product, the provisions of the applicable technical regulation, and the chosen conformity assessment scheme.

State registration timelines: from 3 months.

Official State Fees for Product Certification (TR CU):

State fee for the Certificate of State Registration (SGR) – see the section “Dietary Supplements Registration“.

Our Service Fees for Product Certification (TR CU):

Our service pricing for certification and declaration support is project-based and depends on:

1. Product characteristics;
2. Certification parameters (applicable technical regulations, selected certification/declaration scheme, required testing scope);
3. Additional services (document preparation, translation, etc.).

To determine exact costs, please provide product documentation for our experts’ analysis and detailed quotation.

Core Regulatory Framework for Product Certification (TR CU):

1. Treaty on the Eurasian Economic Union of May 29, 2014;
2. Appendix No. 9 to the EAEU Treaty “Protocol on Technical Regulation within the Framework of the Eurasian Economic Union”;
3. EEC Council Decision No. 80 of September 14, 2021 “On Approval of the Unified Commodity Nomenclature of Foreign Economic Activity of the Eurasian Economic Union and the Common Customs Tariff of the Eurasian Economic Union, as well as on Amending and Repealing Certain Decisions of the Council of the Eurasian Economic Commission”;
4. EEC Council Decision No. 130 of November 12, 2021 “On the Procedure for Importing Products Subject to Mandatory Conformity Assessment into the Customs Territory of the Eurasian Economic Union”;
5. EEC Board Decision No. 293 of December 25, 2012 “On Uniform Forms of Certificates of Conformity and Declarations of Conformity with the Requirements of Technical Regulations of the Eurasian Economic Union and the Rules for Their Registration”;
6. EEC Council Decision No. 44 of April 18, 2018 “On Standard Conformity Assessment Schemes”;
7. Decision of the Customs Union Commission No. 526 of January 28, 2011 “On the Unified List of Products Subject to Mandatory Requirements within the Customs Union”;
8. EEC Board Decision No. 80 of June 30, 2017 “On Certificates of State Registration of Products”;
9. EEC Board Decision No. 52 of April 2, 2019 “On the List of Technical Regulations of the Eurasian Economic Union (Technical Regulations of the Customs Union)”;
10. EEC Board Decision No. 46 of April 4, 2023 “On the Unified Register of Issued Certificates of Conformity and Registered Declarations of Conformity”;
11. EEC Board Decision No. 41 of March 20, 2018 “On the Procedure for Registration, Suspension, Resumption, and Termination of Declarations of Conformity of Products with the Requirements of Technical Regulations of the Eurasian Economic Union”;
12. Decision of the Customs Union Commission No. 621 of April 7, 2011 “On the Regulation on the Procedure for Applying Standard Schemes for Assessing (Confirming) Conformity with the Requirements of Technical Regulations of the Customs Union”;
13. Technical Regulations of the Customs Union;
14. Federal Law No. 184-FZ of December 27, 2002 “On Technical Regulation”;
15. Order of the Ministry of Economic Development No. 714 of November 14, 2024 “On the Procedure, Cases, and Amounts of Fees for Entering Information into the Registers of Certificates of Conformity Issued by Accredited Persons, Other Conformity Assessment Documents Issued by Accredited Persons, and into the Registers of Declarations of Conformity, Including the National Part of the Unified Register of Issued Certificates of Conformity and Registered Declarations of Conformity of the Eurasian Economic Union, Providing Information Therefrom, and Registering Declarations of Conformity”.

Product Certification and Declaration Under GOST R Requirements (Russian National System)

GOST R refers to the national standards of quality and safety applicable in the Russian Federation.

Key Difference from TR CU/TR EAEU:

• Valid only in Russia;
• For exports in EAEU required product certification under TR CU/TR EAEU.

Mandatory conformity assessment is legally required for products included in Government Resolution No. 2425 of December 23, 2021 “On approval of a unified list of products subject to mandatory certification and a unified list of products subject to declaration of conformity, amendments to Russian Government Resolution No. 2467 of December 31, 2020, and revocation of certain acts of the Russian Government”, which guarantees their safety and compliance with national standards.

Without this procedure, the release of such products to the market is prohibited!

There are two principal methods of mandatory conformity assessment for products subject to national standards:

1. Product Certification – a procedure in which an independent certification body verifies and formally confirms that the product meets the established standards. The outcome is the issuance of a Certificate of Conformity;
2. Declaration of Conformity – a form of conformity assessment in which the manufacturer or supplier assumes responsibility for the product’s compliance with the standard requirements by registering a Declaration of Conformity.

Voluntary certification is conducted at the applicant’s initiative (manufacturer, importer, seller) to enhance competitiveness and market position.

In accordance with Order No. 3358 of December 26, 2019, issued by Rosstandart (the Federal Agency for Technical Regulation and Metrology), several voluntary certification systems were abolished on the territory of the Russian Federation.

To replace the abolished systems, Rosstandart established the National Certification System as the primary framework for voluntary conformity assessment. This was implemented through:

• Order No. 2033 of December 29, 2016, establishing the National Certification System;
• Order No. 689 of April 3, 2017, appointing FGBU “RST” (the Russian Standardization Institute) as the system operator.

Today, the National Certification System serves as the principal structure for voluntary product certification in Russia, offering manufacturers a transparent and legally recognized pathway to demonstrate product quality beyond mandatory requirements.

Types of Conformity Documents for Product Certification (GOST R):

Key Terminology for Product Certification (GOST R):

• Rosstandart: Federal Agency for Technical Regulation and Metrology;
• FGBU “RST”: Federal State Budgetary Institution “Russian Standardization Institute”, subordinate to Rosstandart (operator of National Certification System);
• Manufacturer: A legal entity or an individual entrepreneur (including foreign) that manufactures or manufactures and sells products on their own behalf and is responsible for their compliance with established requirements;
• Authorized Representative (AR): A legal entity or an individual entrepreneur registered in the Russian Federation that, under contract with a manufacturer (including foreign), performs conformity assessment and places products on the Russian market (including products imported into the Russian Federation), assuming responsibility for any non-compliance with established requirements;
• Seller: A legal entity or an individual entrepreneur registered in the Russian Federation who sells products under contracts and is not a manufacturer;
• Importer: A legal entity or an individual entrepreneur registered in the Russian Federation that imports products under foreign trade contract and places them on the Russian market, assuming responsibility for their compliance with established requirements;
• Accredited Testing Laboratory (Center): A testing laboratory (center) accredited in accordance with Russian legislation on accreditation in the national accreditation system, which carries out research (testing) and measurements;
• Analysis of Production Condition (APC): An element of the certification scheme, representing a set of actions performed by the certification body to determine whether the manufacturer has the necessary conditions to ensure the continuous (stable) compliance of its products with the requirements confirmed (validated) during mandatory certification.

Conformity Procedure for Product Certification (GOST R) Includes:

• Laboratory testing of samples;
• Analysis of technical documentation;
• Production control (for serial production);
• Inspection control (for certified products).

Estimated Timelines for Product Certification (GOST R):

The timelines for product certification and declaration under national standards depend on the type of product, the requirements of the applicable national standard, and the chosen conformity assessment scheme.

Official State Fees for Product Certification (GOST R):

Our Service Fees for Product Certification (GOST R):

Our service pricing for certification and declaration support is project-based and depends on:

1. Product characteristics;
2. Certification parameters (applicable national standarts, selected certification/declaration scheme, required testing scope);
3. Additional services (document preparation, translation, etc.).

To determine exact costs, please provide product documentation for our experts’ analysis and detailed quotation.

Liability for Non-Compliance:

• Prohibition on import and sale of products;
• Product confiscation;
• Administrative fines;
• Criminal liability in case of harm caused.

Core Regulatory Framework for Product Certification (GOST R):

1. Federal Law No. 184-FZ of December 27, 2002 “On Technical Regulation”;
2. Government Resolution No. 1265 of July 24, 2021 “On Approval of the Rules for Mandatory Confirmation of Conformity of Products Specified in the First Paragraph of Clause 3 of Article 46 of the Federal Law “On Technical Regulation”;
3. Government Resolution No. 2425 of December 23, 2021 “On Approval of a Unified List of Products Subject to Mandatory Certification and a Unified List of Products Subject to Declaration of Conformity, Amending Resolution of the Government of the Russian Federation No. 2467 of December 31, 2020, and Recognizing as Invalid Certain Acts of the Government of the Russian Federation”;
4. Government Resolution No. 936 of June 19, 2021 “On the Procedure for Registering, Suspension, Renewal, and Termination of Declarations of Conformity, and Recognizing Them as Invalid, and the Procedure for Suspension, Renewal, Termination, and Invalidation of Certificates of Conformity”;
5. Order of the Ministry of Economic Development No. 714 of November 14, 2024 “On the Procedure, Cases, and Amounts of Fees for Entering Information into the Registers of Certificates of Conformity Issued by Accredited Persons, Other Conformity Assessment Documents Issued by Accredited Persons, into the Registers of Declarations of Conformity, Including the National Part of the Unified Register of Issued Certificates of Conformity and Registered Declarations of Conformity of the Eurasian Economic Union, Providing Information Therefrom, and Registering Declarations of Conformity”;
6. GOST R 51293-2022 “Conformity Assessment. General Rules for Product Identification for the Purposes of Conformity Confirmation”;
7. GOST R 58972-2020 “Conformity Assessment. General Rules for Sampling for Product Testing during Conformity Confirmation”;
8. GOST R 53603-2020 “Conformity Assessment. Product Certification Schemes in the Russian Federation”;
9. GOST R 54008-2022 “Conformity Assessment. Declaration of Conformity Schemes”.

Need guidance on product certification or declaration in the EAEU or Russia? Contact our experts for a free consultation.