CU TR Certificate of Conformity & Declaration of Conformity (TR TS / EAC)

Terminology clarification

• CU TR / TR TS / TR CU: Technical Regulations of the Customs Union (Технический регламент Таможенного союза, ТР ТС). After the Customs Union evolved into EAEU, newer regulations are named TR EAEU. In daily export practice, people still use TR TS / CU TR interchangeably.

• EAC: The unified conformity marking for products complying with TR TS / TR EAEU.

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• Two mandatory conformity documents under TR TS:

1. Certificate of Conformity (Сертификат соответствия ТР ТС) — CoC

2. Declaration of Conformity (Декларация соответствия ТР ТС) — DoC

Both documents allow customs clearance and product sales across all 5 EAEU member states. The applicable TR TS defines which document you must obtain; you cannot pick freely.

1. CU TR Certificate of Conformity (CoC)

Applicable to high-risk products specified in the relevant TR TS.

• Issuer: EAEU accredited notified certification body (listed in the EAEU unified register).

• Assessment procedure:

• Scheme 1C (mass/serial production): product sample testing + factory quality audit; valid for 1–5 years, requires annual surveillance audit and periodic retesting.

• Scheme 3C (batch shipment): only sample testing, no factory audit; valid only for the stated batch quantity, no annual surveillance.

• Scheme 4C: for single unique equipment / project items.

• Document features: printed on special security numbered paper, stamped and signed by the certification body.

• Liability: shared liability between the notified certification body and the EAEU Authorised Representative (AR, applicant).

• Typical product scope:

• Toys (TR TS 008/2011)

• Children’s products (TR TS 007/2011)

• Machinery and equipment (TR TS 010/2011)

• Pressure equipment (TR TS 032/2013)

• Explosion-proof equipment, lifts, amusement rides

• PPE (personal protective equipment, TR TS 019/2011)

• Motor vehicles, tyres (TR TS 018/2011)

• Fire safety products

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2. CU TR Declaration of Conformity (DoC)

Applicable to medium & low-risk products specified in the relevant TR TS.

• Issuer: drawn up and signed by the EAEU Authorised Representative (AR); an accredited body registers it in the FGIS unified database.

• Assessment procedure: sample testing in accredited lab is mandatory. No factory audit required.

• Scheme 1D / 2D for serial production (valid up to 5 years).

• Scheme 3D /4D for one single batch/consignment.

• Document features: plain paper, signed by AR; electronic version is legally valid once FGIS registration is complete.

• Liability: the EAEU AR bears full legal responsibility for product compliance. The registering body only checks document completeness, it does not guarantee product quality.

• Typical product scope:

• Low voltage equipment (TR TS 004/2011)

• EMC (TR TS 020/2011)

• EAEU RoHS (TR EAEU 037/2016)

• Furniture, textiles, adult clothing, footwear

• Food contact materials & packaging (TR TS 005/2011)

• Hand tools, fans, pumps, insulation and many construction materials

Comparison table

Common key rules for both CoC and DoC

1. Non-EAEU manufacturers must appoint an EAEU Authorised Representative registered in an EAEU country to act as the applicant.

2. Both must be registered in FGIS (Federal State Information System). Unregistered documents are invalid and rejected by customs and market surveillance.

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4. The EAC mark graphic is identical for CoC and DoC products.

5. The full technical dossier must be preserved for at least 10 years after document expiry / last batch release and ready for inspection.

6. Product labels, operation manual / product passport must contain Russian text (English can be added as supplementary).

Common misconceptions

1. ❌ DoC = no testing. ✔ DoC must rely on accredited lab test protocols; you cannot register DoC without test evidence.

2. ❌ CoC can replace DoC freely. ✔ If TR TS only mandates DoC, CoC is voluntary certification and unnecessary.

3. ❌ EAC mark is the certificate. ✔ EAC is the marking logo; CoC / DoC are the underlying legal conformity documents.