An importer may have a supplier’s vehicle approval, a cross-reference to an original part number and a test report, yet still have no document that covers the replacement part it plans to sell. For EAEU conformity, start with the component itself. Identify its function, the vehicles it fits and how it will reach the market. That information determines whether to use the component route in TR CU 018/2011 and which evidence belongs in the file.
Reestr Garant helps overseas manufacturers and importers assess automotive components for Russia and other Eurasian Economic Union markets. We check the proposed product scope, match existing evidence to the parts and help coordinate the applicable conformity assessment before stock is shipped or advertised.
When a vehicle component needs its own assessment
TR CU 018/2011 governs the safety of wheeled vehicles and includes requirements for particular component types. Annex 10 is the starting point for checking the requirements and permitted conformity routes for a covered component. A description such as “vehicle spare parts” is too broad for this purpose. A lighting unit, a brake component and a trim part each serve a different function, even when the same distributor sells all three for the same vehicle.
Establish whether the component is intended for original vehicle assembly, sold as a new aftermarket replacement, offered in a conversion kit, or supplied in a used or remanufactured condition. The regulation treats some assembly supplies and certain used or restored components differently from new replacements. In particular, a supply to a vehicle assembly plant can still require an individual component check if the applicable UN regulation calls for it. Keep evidence of the actual supply arrangement and check the conditions before treating an item as excluded from component conformity assessment.
Component conformity and vehicle approval are separate decisions
A vehicle type approval is tied to the vehicle type and its approved configuration. When a supplier uses it as supporting evidence, the file should connect the approved vehicle and the actual component, including the relevant part number, revision and manufacturer. A catalogue entry saying that a part fits the same model is useful for identifying fitment, but it does not establish that the supplier's version is identical to the part covered by the approval.
An installer making a vehicle conversion may also face a separate review of the modified vehicle. A compliant component can still be unsuitable for a particular installation. For example, when reviewing a proposed replacement lamp, record the lamp’s functions, markings, intended position and vehicle category. A change from the approved installation raises a separate question for the vehicle, regardless of what the lamp’s own documents show.
How we identify the certification or declaration route
- Identify the part. Match the drawing, sample and commercial part number. Record whether the part is sold alone, with a bracket or controller, or as an assembled kit.
- Describe the fitment. Confirm the vehicle category, intended models or platforms, position and safety function. A part sold for several vehicle types may need more than one fitment record.
- Check the applicable requirements. Compare the component with Annex 10 and any UN regulation referenced for that component. Where conformity assessment applies, confirm the form and scheme for the specific entry. A required certificate cannot be replaced by an informal test report.
- Confirm the applicant and evidence. Determine who can apply under the selected route and whether existing approval or test documents cover the actual component. If gaps remain, identify what must be supplied or tested.
- Check the result before dispatch. Compare the issued or registered document and its attachments with the parts, manufacturer and applicable markings. For a batch assessment, match the invoice or lot identification to the batch being shipped.
What to send for the initial review
- A list of commercial part numbers, engineering drawing numbers and revisions, with photographs of the product and its markings.
- The legal manufacturer, production site and intended distribution arrangement. Explain whether the product will be shipped for assembly or offered in the aftermarket.
- A fitment list with the intended vehicle category, model or platform, location on the vehicle and function.
- Drawings and a material or component description. For a kit, list all included parts and identify the function of the assembled kit.
- Copies of any existing UN approvals, test reports or conformity documents, including their appendices. A file number alone rarely shows which version was assessed.
- The destination market, expected supply pattern and first shipment schedule. Indicate whether this is a one-off batch or repeat production.
How test samples relate to the models in the file
The objective is to show why the proposed sample represents the components to be supplied. A change to a material, a structural dimension, a lighting function, a sealing arrangement or a control module can affect the assessment. Before sending samples, identify the variants and ask the assessment body which construction or configuration it can use for testing. Where a change affects the evidence, update the file before adding the variant to the catalogue or shipment.
Check report identity as carefully as the results. For instance, a part number on the shipping label may be a distributor code, while the report uses an engineering number. Provide a signed cross-reference and drawing revision so the relationship can be reviewed. If a document cites an approval number but has no attachment listing models or configurations, ask the supplier for the complete record before relying on it.
What the service covers and how we quote
We review the parts list and drawings, document the likely route for each group and identify missing evidence. Once you confirm the scope, we can help prepare the file and coordinate with the appropriate certification body or laboratory. The certification body makes the certification decision. Where a declaration applies, the eligible applicant assumes the responsibilities attached to that route.
The quotation depends on how many distinct component types and configurations must be reviewed, which reports are available, and whether new samples, translations or production assessment are needed. A large catalogue can sometimes share evidence across variants, but grouping depends on the technical differences and applicable scheme. Send the first shipment list and one complete sample file if you want to start with the parts that will reach the market first.
Frequently asked questions
Does every imported automotive part require an EAC certificate?
The route depends on the part’s function, the scope of TR CU 018/2011 and the relevant component entry. The regulation allows different assessment routes for covered types and sets conditions for cases where component assessment does not apply.
Can we use the vehicle manufacturer’s approval for our replacement part?
Provide the approval with its attachments and evidence connecting your exact part and revision to the approved configuration. We can check whether it supports the proposed route or whether separate evidence is needed.
Can different part numbers share one assessment?
Sometimes. Identify why the numbers differ and which design, materials, function and fitment characteristics they share. The applicable scheme and the assessment body determine whether one test plan can cover them.
What should we send before placing a repeat order?
Send the current parts list, drawings or revision history and the previous certificate or declaration with its attachments. Highlight any change in production site, part construction, supplier identification or fitment since the last order.
Compare the certificate and declaration routes and check what evidence applies to your product.