Learn more about the TR CU HBO certificate
Certificate of compliance with the Technical Regulations of the Eurasian Economic Union.
In this article, we will look at what a certificate of conformity is, certification schemes, and what you need to get a certificate.
So, what is a certificate of conformity?
The certificate of conformity is a document confirming that the products meet the requirements and conditions of the Technical Regulations of the EAEU.
The certificate is issued in a single form on a special form established by the Eurasian Economic Union and is issued by a certification body accredited by Rosaccreditation. The uniform form of the certificate of conformity is established by the decision of the Board of the Unified Economic Commission of November 15, 2016 No. 154 "On Amendments to the Decision of the Unified Economic Commission of December 25, 2012 No. 293"
Let's look at what a certificate is.
If we certify a product and it has many models or branches of the manufacturer that do not fit on the form, then they are indicated in the appendices to the certificate.
Application with a list of branches:
Application with a list of models:
Each form contains the number of the certificate of conformity assigned during registration, and the series and number of the form.
The number of the certificate of conformity is formed according to the "Rules for the formation of registration numbers of certificates of conformity and declarations of conformity in the registers of Rosaccreditation" dated June 28, 2018.
Consider the certificate number: < b> No. of the EAEU RU C-IT. HX37.B. 00049/20
RU-the designation of the country in which the certificate was issued (a member state of the EAEU);
C-indicates that this document is a certificate;
IT – the country of manufacture of the product (in this example, Italy);
NH37-designation of the certification body that issued the certificate;
B-indicates that the document is issued for serial production;
next is the certificate number and year of manufacture.
Let's look at how the rows in the certificate are filled in.
In the upper field of the certificate, specify the name and address of the certification body, as well as the number of the accreditation certificate and the date of issue of the certificate.
The line "applicant" contains full information about the applicant, namely: the full name of the organization, legal address, phone number and e-mail.
The line "manufacturer" contains full information about the manufacturer: the country in which the plant is located, the full name and address. If the manufacturer, then the name and address are written in English. If the manufacturing country is a member of the EAEU, it is written in the language of that country. All branches of the manufacturer are also indicated. If there are many branches, they are registered in a separate application.
In the line "products", specify the product name, serial number and articles. If there are many models, then they are registered in a separate application. In the same way, the serial or batch production is prescribed and in which directive the products are specified.
The next line is the code of the Commodity Nomenclature of Foreign Economic Activity (HS). The code consists of 10 digits, which must all be specified.
The next line specifies what regulations the products comply with. Not only the number of the technical regulations is written, but also its name.
In the line "certificate of conformity issued on the basis of", indicate the number of the product test report, date, name of the testing laboratory and the number of the accreditation certificate of this laboratory.
Now let's look at the certification schemes: there are 9 of them in total. (the scheme below)
Certification schemes are established by the Decision of the EEC Council No. 44 of April 18, 2018 "On Standard Conformity Assessment Schemes»
Now let's look at the most common schemes (from my personal practice).
These are schemes 1c and 3c.
So, < b>1c certification scheme.
This certification scheme is for serial products. The number of models in the serial production is not limited. To obtain a certificate of conformity, a mandatory condition will be to conduct tests with the subsequent issuance of a test report. In the certification scheme under consideration, not only product tests are performed, but also the departure of an OS expert to analyze the state of production. The analysis of the production status is carried out in accordance with GOST R 54293-2020 "Analysis of the production status when confirming compliance". During the production analysis, the expert of the certification body checks how the products are produced, whether the safety measures in the workshops are observed, the technical documentation in accordance with which the production is carried out, whether the products are rejected. After conducting the production analysis, the OS expert draws up a report on the analysis of the state of production in two copies (one copy remains in the OS, and the second is issued to the applicant). Under this scheme, the certificate is valid for no more than 5 years from the date of issue and during the entire validity period of the certificate, an annual inspection control (IR) must be carried out. The IR is conducted by the OS that issued the certificate. Inspection control is carried out in accordance with GOST 31815-2012 " Conformity assessment. The procedure for conducting inspection control in certification procedures". The annual IR is necessary in order to keep track of the production process and after the certificate is issued.
The applicant in this scheme can be the manufacturer himself, if he is a resident of the EAEU, or a person authorized by the manufacturer in the territory of the Customs Union.
3c certification scheme.
This scheme is provided when a batch of products is certified, and in this case the number of certified products is limited to the number of models in the batch. As in the 1c scheme, here the test report will be a mandatory document for obtaining a certificate. But there is a difference in this scheme, namely, the lack of production analysis and subsequent inspection control. The applicant selects the test samples.
The applicant here can be a seller( supplier), manufacturer, if it is located on the territory of the EAEU.
So, what does it take to get a certificate?
To register a certificate, you must:
1. The applicant makes a request in accordance with the form of OS in which he gives full name, legal address, name of Director. You must also specify the full name of the certified device, the series (model) and article number, if available, and the trademark. Specify the manufacturer of the product and its address, for how many years the certificate is issued, for a series or batch. You also need to specify the HS code.
2. Statutory documents: certified copies of the TIN and OGRN, as well as the Charter. Or is certified by the certificate of incorporation, if the applicant is an individual to take the necessary it was, and extract from the egrip.
3. If the manufacturer is not the applicant, then a contract of the person authorized by the manufacturer (the contract of the UIL) signed by both parties is required. A UIL contract is required if the certificate is issued for a series. If a certificate is issued for the batch, then a contract and invoice are required. In this case, the UIL will not be required.
4. If the manufacturer is a Russian company, you will need to provide a technical specification (TU), which should describe in detail the product, its technical characteristics, scope of application, and how the device looks. If the manufacturer is a foreign person, it will be necessary to provide a technical description (TO). In which you also need a detailed description of the device, all the claimed models, a photo of the model, technical characteristics and scope of application.
5. The experts of the certification body where we issue the certificate of conformity go to the production site where the certified products are produced. There, OS experts conduct an analysis of production, look at how production is being produced, and visit production workshops. In the event that there will be a negative result of the production analysis and the certificate will not be issued, as well as there will be no testing of samples. If the result is positive, we will need to provide samples for testing and this is discussed in the next paragraph.
6. A mandatory condition for the issue of the certificate is the testing of samples. As mentioned above, without conducting tests and issuing a test report, we will not be issued a certificate of compliance. In order for the sample to be tested, you must receive a letter from the certification body for the import of samples. This letter should include the model and its article number (if available) and the manufacturer of the product and its address. The model number of the sample must fully correspond to the model specified in the letter and in the application for certification. Also, the model must be marked, which must correspond to the application.
(below is an example of labeling)
Further, the sample is tested and, if the sample has passed the tests, a certificate of conformity is issued.
Will the samples be returned?
They must, according to GOST 31814-2012 " Conformity assessment. General rules for sampling for testing products in conformity assessment " p. 3.12 at the end of the research (testing) and measurements, the samples are returned to the applicant, except in cases where the applicant, with the consent of the certification body, the testing laboratory (center), considers the return of samples impractical.
Of course, the Authority can try to agree in advance that the samples remain in the laboratory as control samples, but you have the right to refuse.
Can samples be sold after testing?
The law does not prohibit it. Moreover, many products are imported in single copies, they are also tested. In order to do this legally, you need to make an adjustment to the DT (customs declaration): provide a certificate and remove the mark "sample" (061), leaving only the 4000 issue for domestic consumption.
Certificate of conformity
The main form of confirmation of conformity of products to the requirements of technical regulation of the Customs union “On electro-magnetic compatibility of technical means” (TR CU 020 / 2011), approved by Decision of Customs Union Commission No. 879 of 9 December 2011, is certification.
Certification for serial production is performed using scheme 1c. The producer (company authorized by the manufacturer) provides the equipment for certification. Certification for a single batch is performed using scheme 3c. Certification for a single item is performed using scheme 4c. The batch (single item), manufactured on the territory of the CU is provided by the manufacturer, a batch entering the territory of CU is provided by the importer or the manufacturer (company authorized by the manufacturer).
The authorized body: certification according to TR CU 020/2011 should be performed by the authorized certification body, included to the unified register of certification bodies and testing laboratories (centers) of the Customs Union.
Tests for certification are performed by testing laboratory included to the unified register of certification bodies and testing laboratories (centers) of the Customs Union.
It should be noted that serial production certification (scheme 1c) requires factory inspection. The final document of this inspection is factory inspection act, which has big influence on certification body’s decision about the possibility of issuing of the certificate and its validity.
Important: certificate according to TR CU 020/2011 can be valid up to 5 years. Form of certificate of conformity to Technical regulations of the Customs Union approved by Decision of the Collegium of the Eurasian economic Commission of 25 December 2012 № 293 "About unified forms of certificates of conformity and declarations of conformity to technical regulations of the Customs Union and rules of their registration". The certificate is valid on the territory of the CU and has equal force regardless the territory where it was issued.
The product, package and supporting documentation should be labeled by the conformity sign after conformity assessment.
TR CU EMC Declaration of conformity
Another form of confirmation of conformity of the products to requirements of Technical regulations of the Customs Union "On electro-magnetic compatibility of technical means"( TR CU 020 / 2011), approved by Decision of Customs Union Commission No. 879 of 9 December 2011, is declaration of conformity.
Definition: declaration of conformity according to technical regulation of the Custom union “On electro-magnetic compatibility of technical means” – is the document, proving the conformity of the product to mandatory requirements of TR CU “On electro-magnetic compatibility of technical means”. Declaration can be issued for the manufacturer (an authorized representative on the territory of the CU), importer (batch declaration), duly registered on the territory of the Custom union.
Declaration can be issued only for technical means capable to create electromagnetic interference and (or) the quality of functioning of which depends on exposure to external electromagnetic interference, and not included in the list of technical means, subject to certification according to technical regulation of the Custom union “On electro-magnetic compatibility of technical means” (in appendix to TR CU 020/2011 ).
Declaration can’t be issued voluntarily, if the product is out of the scope of technical regulation or the product is subject to mandatory certification. But the applicant at his will can change declaration to certification according to the requirements of technical regulation “On electro-magnetic compatibility of technical means”.
Depending on the product and method of production (serial production, batch, single item), the applicant can choose one of the schemes of declaration specified in technical regulation “On electro-magnetic compatibility of technical means” (1d, 2d, 3d, 4d, 6d). It should be noted, that TR CU 020/2011 doesn’t consist declaration according to scheme 5d, consequently the applicant can’t use this scheme.
Typical schemes of declaration of conformity to the requirements of technical regulations of the Custom union (1d, 2d, 3d, 4d, 5d, 6d), are established by Decision of the CU Commission of 7 April 2011 No. 621 "On the Situation on the procedure for application of standard schemes of evaluation (confirmation) of compliance to requirements of technical regulations of the Customs Union".
The authorized body: for registration of the declaration of conformity to the requirements of TR CU 020/2011, the applicant applies to an accredited certification body, and after a couple of days after receiving information about the registration of the declaration he can check the declaration in the register of registered declarations of conformity issued according to unified form.
The decision of the Board Eurasian economic Commission of 25 December 2012 № 293 "About unified forms of certificate of conformity and declaration of conformity to technical regulations of the Customs Union and rules of their registration", approved unified form of declaration of conformity to technical regulations of the Customs Union. The main difference of TR CU declaration of conformity from usual GOST R declaration is lack of stamp of certification body, who registered it. Unlike GOST R declarations, TR CU declarations entered in the unified register of registered declarations of conformity issued according to unified form, which leads the Federal service on accreditation.
For registration of the declaration of conformity according to TR CU 020/2011 evidence base should be provided to the accredited certification body in accordance with the chosen scheme of the declaration. Declaration of conformity of technical means manufactured serially, is carried by the manufacturer (manufacturer's authorized person) under schemes 1d, 3d, 6d. Declaration of conformity on a batch of technical means (or single item) is carried by the manufacturer (manufacturer's authorized person) under schemes 2d, 4d.
Important: all responsibility for the inaccuracy of the declared information on the conformity of products to requirements of Technical regulations of the Customs Union, is on the applicant (declarant). Declaration of conformity according to TR CU “On electro-magnetic compatibility of technical means” can be issued up to 5 years and is valid on the territory of CU and has equal force regardless the territory where it was issued.
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