EAC certificate for LED lighting in Russia and the EAEU

Product identification comes first

Does LED lighting need an EAC Certificate of Conformity?

Not always. The required document depends on the actual product, its electrical characteristics, intended use, product classification, and the EAEU regulations that apply to the separately placed product. The route may involve an EAC Certificate of Conformity, an EAC Declaration of Conformity, or another assessment determined after the product is classified.

An LED lamp, a complete luminaire, an LED module, a driver, a power supply, and a lighting system are not automatically the same product for conformity assessment. A product-specific review must take place before testing, document preparation, or EAC marking. The word “LED” describes the technology, but it does not determine the legal route.

Reestr Garant helps foreign manufacturers, exporters, importers, and distributors assess LED lighting for supply in Russia and the EAEU. The service covers product identification, review of applicable regulations, applicant arrangements, evidence preparation, testing coordination, document checks, and EAC marking support. The exact service scope is established after the product data has been reviewed.

The first decision is therefore practical: identify what will actually be placed on the market. A replacement lamp sold separately has a different scope from a luminaire supplied with an integrated LED module. A 24V luminaire supplied with a 220V adapter also requires the adapter to be considered as part of the supplied configuration.

LED lamp, luminaire, or complete lighting system?

A replaceable LED lamp is a distinct product category from a luminaire, which is a complete lighting fitting. An EAC certificate issued for a luminaire does not cover standalone replaceable lamps. The manufacturer, importer, and distributor should compare the document scope with the exact goods in the shipment rather than relying on a broad catalog description.

Built-in LED modules and internal drivers are assessed as part of the complete luminaire when they form part of the supplied product. If an LED module, driver, or power supply is sold or imported separately, it becomes a separately placed product and requires its own conformity assessment according to the regulations that apply to that product.

This distinction matters for a company researching luminaire EAC certification. The relevant document must identify the complete luminaire and its covered configuration. It should not be assumed to cover a replacement lamp, an independent driver, or a different finished product merely because the products are used together.

What product information changes the route?

The assessment team needs enough information to distinguish the product and its variants. The following attributes can change the applicable document, evidence, or assessment scheme:

Product attribute	Why it changes the route	Evidence needed
Product type	A replaceable lamp, luminaire, driver, module, and complete system may have different scopes.	Product description, photographs, drawings, and model list.
Rated voltage	Voltage determines whether TR CU 004/2011 may apply to the equipment.	Electrical specifications, rating label, and circuit information.
Power supply	An integrated driver and a separately supplied adapter may require different assessment treatment.	Driver data, adapter data, wiring diagram, and kit configuration.
Intended use	Household, commercial, industrial, warehouse, and street luminaires may follow different conformity forms.	Instructions, installation conditions, catalog description, and use designation.
Model differences	Construction and critical components determine whether models can share one document.	Variant list, technical comparison, component list, and drawings.
Control functions	Dimming, switching, and other electronic functions affect the technical evidence to be reviewed.	Operating modes, wiring diagrams, controller information, and test reports.
Ingress protection	The declared IP rating concerns the fully assembled luminaire housing.	Laboratory test evidence for the assembled product.
Supply format	A serial product, batch, or single item may use different assessment schemes.	Production information, shipment details, and manufacturing documents.

Multiple luminaire models may be combined in one certificate only when they form a technically homogeneous group. The group must share the same manufacturer, basic construction, intended use, and critical components. Cosmetic differences such as body color, decorative finishes, or shade shapes may remain within one document when they do not change heat dissipation, creepage distances, or other safety parameters.

Replacing a critical component after certification requires particular care. A change to an LED driver or power supply unit requires a review of whether the existing evidence covers the changed product and whether reassessment or additional testing is needed. The model list should therefore be finalized together with the component configuration, not after testing.

Regulations and other controls to check

The applicable requirements are identified after the product has been classified. For many LED products, the initial review concerns TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016, but these regulations do not apply in an identical way to every lamp, luminaire, driver, or system.

TR CU 004/2011 On safety of low-voltage equipment

TR CU 004/2011 applies to electrical equipment operating at rated voltages from 50 to 1000 V AC and from 75 to 1500 V DC. It regulates electrical and mechanical safety within its scope. The voltage, finished configuration, product type, and any applicable exclusions must be reviewed before the regulation is assigned to a product.

A low-voltage luminaire supplied at 12V or 24V DC may fall below the voltage threshold of TR CU 004/2011 for the luminaire itself. That does not remove the need to assess an external 220V mains power adapter supplied in the kit. The adapter is a separate electrical element with its own characteristics and must be considered in the conformity route for the supplied product.

Household luminaires and chandeliers included in the mandatory certification list of TR CU 004/2011 are subject to mandatory certification by an accredited certification body. Industrial, commercial, warehouse, and street luminaires that are not included in that mandatory household certification list are generally confirmed through an EAC Declaration of Conformity when they remain within the regulation’s scope.

The final form is determined after classification. Each regulation identifies products subject to certification, while other in-scope products are normally declared. Certification may replace declaration at the applicant’s choice where the applicable rules permit it, and certification is required where specified standards are not applied or are absent under the applicable regulation.

TR CU 020/2011 Electromagnetic compatibility of technical devices

TR CU 020/2011 regulates the ability of equipment to operate in an electromagnetic environment without creating unacceptable interference and with sufficient immunity to interference. LED drivers, switching circuits, dimming equipment, and electronic control functions can affect the EMC evidence required for a luminaire.

The product should not be treated as outside EMC requirements merely because its main function is lighting. The actual design, operating modes, and included electrical components must be reviewed. Used equipment is excluded from TR CU 020/2011, but that exclusion does not automatically remove the product from every other applicable regulation.

An EMC test report can support the procedure only when it corresponds to the product configuration and the requirements of the selected assessment route. A report for one driver, voltage, or control arrangement does not automatically support a different finished luminaire.

TR EAEU 037/2016 On restriction of the use of hazardous substances in electrical and radio electronic products

TR EAEU 037/2016 restricts the content of specified hazardous substances in electrical and radioelectronic products placed on the EAEU market. The substances covered include lead, cadmium, mercury, hexavalent chromium, PBB, and PBDE.

Conformity with TR EAEU 037/2016 must be established independently from conformity with TR CU 004/2011 and TR CU 020/2011. A document under one regulation does not substitute for compliance with another. The applicable form for TR EAEU 037/2016 depends on the product’s classification and the provisions applicable to it; a declaration can be replaced by certification under Article 7(10) where that provision applies.

Technical evidence for restricted substances should correspond to the actual product and components. The assessment should cover the separately placed item, not only a marketing family name or a general statement about LED technology.

Energy efficiency and performance claims

Energy-efficiency requirements may apply to some lamps and luminaires; applicability is checked during classification. The use of LED technology alone does not prove that a particular energy-related document is required.

The EAC mark confirms conformity with all applicable EAEU technical regulations established through the relevant procedure. It does not verify marketing claims about high energy efficiency, luminous efficacy, or electricity savings. Those claims require separate supporting test evidence where they are used in commercial materials or technical documentation.

Other controls and the unified product lists

The unified product lists and applicable EAEU legal instruments help determine whether mandatory conformity assessment applies. The product description, technical characteristics, customs classification, and applicable regulation must be considered together. A general search result or a supplier’s description cannot replace this product-specific review.

GOST standards may be relevant when they have a legal connection to the applicable technical regulation or are used as an appropriate technical basis. A GOST standard is not mandatory merely because it is commonly used in the lighting industry. The legal basis, edition, scope, and role in the assessment must be established before it is presented as required.

CE marking, IEC reports, UL documents, and RoHS-related evidence may provide useful technical information, but they do not replace an EAC Certificate of Conformity or an EAC Declaration of Conformity when EAEU assessment is mandatory. ISO certification concerns a management system and is not product-specific EAC conformity assessment.

Applicant in the EAEU

Who can act as the applicant? The applicant for an EAC Certificate of Conformity or EAC Declaration of Conformity must be a legal entity or registered individual entrepreneur in an EAEU member state. A manufacturer without an eligible EAEU-registered legal entity or individual entrepreneur cannot act as the applicant directly.

For serial production schemes, the applicant may be an EAEU manufacturer or an authorised representative of a foreign manufacturer under an official representation contract. An importer or seller may have a role in the supply chain, but neither role automatically makes that party the correct applicant for every procedure.

The applicant is a legal participant in the conformity assessment. The applicant provides evidence, adopts and registers a declaration where that form applies, communicates with the certification body or other participants, and assumes the responsibilities established by the applicable procedure. The manufacturer remains a distinct entity even when an authorised representative acts for the manufacturer in the EAEU.

The applicant should be selected before the document is finalized. Its legal name, EAEU registration details, relationship with the foreign manufacturer, and responsibility for the product evidence should match the actual supply arrangement. A nominal applicant with no reliable access to the technical file creates a document-control problem for later shipments and changes.

Certification and declaration assign different responsibilities

An EAC Certificate of Conformity is issued and registered by an accredited certification body with an appropriate scope of accreditation. The certification body evaluates the test reports and other required evidence and may perform the production-related assessment required by the selected scheme.

An EAC Declaration of Conformity is adopted and electronically registered by the applicant. The applicant has the responsibilities established by the applicable procedure for the evidence and conformity of the product. Registration of a declaration does not convert it into a certificate and does not transfer the applicant’s responsibility to a laboratory.

Document	Responsible actor	Practical consequence
EAC Certificate of Conformity	Accredited certification body	The body issues and registers the certificate after the required assessment.
EAC Declaration of Conformity	Applicant	The applicant adopts and electronically registers the declaration and remains legally responsible for the evidence and product conformity.
Test report	Accredited testing laboratory	The report records test results; it does not itself authorize EAC marking or replace a registered conformity document.

Rosaccreditation, also known as the Federal Accreditation Service, does not issue certificates or declarations directly. It accredits certification bodies and testing laboratories and operates the official unified electronic registers. The certification body and laboratory must be distinguished from a service coordinator or document-preparation provider.

Documents and samples

The evidence file is prepared for the actual product and the selected conformity route. The exact document set is determined after classification, but a useful initial package normally includes the following information:

• manufacturer name and address;
• manufacturing-site information;
• commercial product name and product category;
• model and variant list;
• rated voltage, frequency, current, and power;
• technical specifications and product drawings;
• product photographs and rating-label information;
• wiring diagrams and operating modes;
• LED module, driver, power supply, and control-unit information;
• intended use and installation environment;
• operating manual and installation instructions;
• packaging and accompanying-document information;
• existing test reports and other technical evidence;
• information about the EAEU applicant;
• the proposed HS or TN VED code and customs description.

The model list should explain which variants are technically equivalent and which differences are material. A family grouping requires more than a similar appearance. The manufacturer should identify the basic construction, intended use, thermal design, insulation, creepage distances, driver, power supply, and other critical components that determine whether the products can be assessed together.

Samples must be tested by an accredited laboratory where the applicable certification or declaration scheme requires it. The laboratory issues a formal test report. The test report is evidence for the procedure. It is not an EAC Certificate of Conformity, an EAC Declaration of Conformity, or permission to apply the EAC mark.

Separate products in one kit

A luminaire supplied with an external adapter should be described as supplied, including the adapter’s manufacturer, model, input, output, and electrical relationship with the luminaire. If the adapter is imported or sold independently, its separate product status must be reviewed as well.

The same approach applies to a driver, LED module, controller, sensor, or other component that is sold separately. A component assessed as part of a complete luminaire does not automatically carry that assessment into a separate shipment. The separately placed product requires its own classification and conformity review.

IP ratings and assembled products

A declared IP protection rating against dust and water applies to the fully assembled luminaire housing. The rating must be verified by laboratory tests on the assembled product and should not be inferred from the specifications of individual components, seals, or enclosure materials.

The laboratory sample should represent the product configuration that the manufacturer will supply. If the tested sample uses a different housing, driver, sealing arrangement, or cable entry from the commercial model, the evidence may not support the intended document scope.

Prepare a model sheet for luminaires with selectable settings

When several luminaires share a housing, list what differs inside each model. Record the LED module, driver part number, rated input, enclosure, installation method and any dimming or control interface. For a model with selectable power or colour temperature, identify all settings a buyer or installer can select. Ask the lab which settings and configurations the test plan will cover and how it will record them.

Check the factory's order confirmation against that sheet before the first shipment. If procurement substitutes a driver or offers an optional controller, trace the part to the tested sample and get a coverage decision from the conformity assessment participants. Keep a separate line for spare drivers sold on their own. Review the input ratings and electromagnetic behaviour using the low-voltage regulation guide and the EMC regulation guide.

Steps before shipment

1. Send product data for classification

The manufacturer or importer provides the model list, technical specifications, voltage information, intended use, component details, product photographs, and available evidence. If the product includes a separate adapter, driver, control unit, or wireless function, that information should be included at the first review.

Reestr Garant then identifies whether the goods are replaceable LED lamps, complete luminaires, drivers, modules, or another product type. The review also considers whether the item is supplied as a serial product, batch, or single item and whether several models can form a technically homogeneous group.

2. Determine applicable regulations and the conformity form

The product is compared with the scope and requirements of TR CU 004/2011, TR CU 020/2011, TR EAEU 037/2016, and any other regulation that becomes relevant after classification. The mandatory product lists and applicable legal provisions are checked for the actual product description.

The outcome may be certification or declaration. Household luminaires and chandeliers included in the mandatory TR CU 004/2011 certification list require certification by an accredited certification body. Industrial, commercial, warehouse, and street luminaires outside that household certification list are generally confirmed through a declaration when they remain within the relevant scope.

3. Confirm the EAEU applicant

The foreign manufacturer identifies the EAEU legal entity or registered individual entrepreneur that will act as applicant. For serial production, the parties also confirm whether the applicant is an EAEU manufacturer or an authorised representative acting under an official representation contract.

The applicant’s identity should match the intended distribution arrangement. The parties should also agree who keeps the technical evidence, who reports product changes, who communicates with the certification body or laboratory, and who controls the final document before shipment.

4. Select the scheme and testing route

Standard certification schemes under TR CU 004/2011 and TR CU 020/2011 include certification scheme 1c for serial production, certification scheme 3c for a batch, and certification scheme 4c for a single item. Scheme 2c is not provided for under TR CU 004/2011.

Typical EAEU conformity assessment schemes are designated in Latin as 1c–9c for certification and 1d–6d for declarations. The applicable scheme depends on the regulation, product status, supply arrangement, and evidence requirements. A scheme designation should not be selected before the product and legal route have been established.

Certification scheme 1c requires periodic inspection control. The regulation does not prescribe an annual frequency in the wording considered here. A serial-production EAC Certificate of Conformity under scheme 1c is valid for up to 5 years. For a batch under scheme 3c or a single item under scheme 4c, no expiration date is established.

5. Complete testing and prepare the document

The accredited testing laboratory tests the product sample required by the procedure and issues a formal test report. The certification body uses the report and other required evidence when deciding whether to issue the EAC Certificate of Conformity. For a declaration, the applicant adopts and electronically registers the EAC Declaration of Conformity on the required evidence basis.

Existing reports are reviewed for model identity, configuration, test scope, laboratory accreditation, and relevance to the selected EAEU procedure. A report prepared for a different driver, voltage, product family, or finished configuration cannot be accepted merely because the commercial product name is similar.

6. Verify the final record before shipment

Certificates and declarations should be checked in the open public registry of FSIS Rosaccreditation by registration number. The check confirms active legal status and the models covered by the record. The manufacturer and importer should compare the registry information with the actual product, applicant, manufacturer, and shipment configuration.

A register entry does not expand the document scope. It does not cover a later design change, a different driver, a new manufacturing site, or a product that was not identified in the certificate or declaration.

Russian labeling, instructions, and the EAC mark

The EAC mark can be applied only after all required conformity assessment procedures have been completed and registered, and before the product is placed into circulation. A test report alone does not authorize the mark.

Customs Union Commission Decision No. 711 establishes the EAC mark’s graphic proportions and application rules. The mark must be clear and legible. The product team should check its placement and visibility against the applicable marking requirements instead of treating the mark as a general logo for the manufacturer.

Operating documents must be in Russian and also in the state language or languages of the EAEU member state where that member state’s legislation requires it. The operating-document language rule should not be confused with every marking requirement. Article 4 separately prescribes marking content and placement.

Product labeling, packaging, and accompanying documents should identify the assessed product accurately. The model name, manufacturer, electrical characteristics, warnings, installation information, and other required data must remain consistent with the technical file and registered conformity document.

The EAC mark confirms conformity with all applicable EAEU technical regulations established under the relevant procedure. It does not confirm marketing statements about electricity savings, high luminous efficacy, or energy performance. Those statements need separate test evidence when the manufacturer uses them.

Timing and price drivers

Processing time is assessed after classification. The available facts do not support a universal period for LED lighting because the route depends on the product, evidence, laboratory work, and production arrangements.

The assessment may take longer when the model range contains materially different products, when several regulations apply, when new testing is needed, when the technical file is incomplete, or when a production-related assessment and inspection control must be organized. A precise time estimate can be made only after these factors are reviewed.

Total certification cost and turnaround time are determined by the number of applicable regulations, the assessment form, model range diversity, testing volume, and production audit logistics. The procedure may also require review of separate drivers, adapters, control units, and other components included in the supplied configuration.

• number of applicable EAEU technical regulations;
• certification or declaration route;
• serial production, batch, or single-item status;
• number and technical diversity of models;
• ability to justify a technically homogeneous product group;
• volume and type of laboratory testing;
• condition and relevance of existing test reports;
• need for production condition analysis or inspection control;
• number of manufacturers and manufacturing sites;
• complexity of drivers, adapters, controls, and power supplies;
• technical-file preparation and translation requirements;
• sample delivery and laboratory logistics.

A fee should not be calculated from the phrase “LED lighting” alone. The product data must first establish what is being assessed, which regulations apply, and whether the intended route is an EAC Certificate of Conformity or an EAC Declaration of Conformity.

Frequent seller mistakes

Using one luminaire certificate for standalone lamps

A luminaire and a replaceable LED lamp are distinct product categories. A certificate for the complete luminaire does not cover standalone lamps removed from that configuration and sold separately.

Changing the driver after certification

The LED driver or power supply is a critical component. Substituting it after certification requires a review of whether the existing compliance evidence covers the changed product and whether reassessment or additional testing is needed. The final component list should be fixed before testing.

Assuming a 24V product has no other regulated equipment

A 12V or 24V DC luminaire may fall below the TR CU 004/2011 voltage threshold, but a 220V adapter supplied with it requires full assessment under that regulation when it falls within the applicable scope. The kit must be analyzed as supplied.

Calling a test report a certificate

An accredited testing laboratory issues a test report. The report records test results, but it does not replace a registered EAC Certificate of Conformity or EAC Declaration of Conformity and does not authorize EAC marking.

Using CE or IEC evidence as the EAEU document

CE marking and IEC evidence may support technical review, but they belong to different systems and do not replace the EAEU conformity document. The same applies to UL and RoHS-related documents.

Choosing the importer without checking applicant status

An importer is not automatically the EAC applicant or holder of the conformity document. The legal entity or registered individual entrepreneur must meet the applicable EAEU applicant requirements, and a foreign manufacturer cannot file directly as applicant.

Relying on an informational refusal letter

An informational refusal letter, also called a non-applicability letter, and a voluntary certificate cannot replace a mandatory EAC Certificate of Conformity or EAC Declaration of Conformity for lighting equipment when the applicable regulation requires mandatory assessment.

Applying the EAC mark before registration

The EAC mark must wait until all required procedures are completed and registered. Applying it to a product outside the registered scope creates a document and labeling discrepancy.

Assuming IP protection from component specifications

The declared IP rating applies to the fully assembled luminaire housing. It must be supported by laboratory testing of the assembled product rather than inferred from the rating of a seal, driver, or enclosure component.

FAQ

Does every LED light require an EAC Certificate of Conformity?

No. The form depends on the actual product classification and applicable EAEU requirements. Some household luminaires and chandeliers included in the mandatory TR CU 004/2011 list require certification, while other in-scope luminaires are generally confirmed through an EAC Declaration of Conformity. The route is determined after the product is classified.

What is the difference between LED lamp certification in Russia and assessment elsewhere in the EAEU?

Russia and the other EAEU member states use the applicable EAEU conformity rules for products within their scope. LED lamp certification in Russia should therefore be assessed as an EAEU product-compliance question, not as a separate assumption based only on the Russian destination. The applicant must meet the EAEU requirements, and the registered document must cover the actual product.

Does a luminaire need its own EAC certification?

A complete luminaire may require its own EAC Certificate of Conformity or EAC Declaration of Conformity, depending on the applicable regulations and product classification. Built-in modules and drivers are reviewed as part of the luminaire; separately sold products require their own classification review. A luminaire certificate does not cover standalone replaceable lamps.

Can CE marking replace an EAC document?

No. CE marking confirms conformity under applicable European Union rules, while the EAC Certificate of Conformity and EAC Declaration of Conformity are based on EAEU requirements. CE, IEC, UL, or RoHS-related evidence may be reviewed as supporting material, but it does not replace the registered EAEU document when mandatory assessment applies.

Who can be the applicant when the manufacturer is outside the EAEU?

The applicant must be a legal entity or registered individual entrepreneur in an EAEU member state. A manufacturer without an eligible EAEU-registered legal entity or individual entrepreneur cannot act as applicant directly. For serial production, the applicant may be an EAEU manufacturer or an authorised representative of the foreign manufacturer under an official representation contract.

Can several luminaire models share one certificate?

They may share one certificate when they form a technically homogeneous group with the same manufacturer, basic construction, intended use, and critical components. Cosmetic differences may be permitted when they do not change heat dissipation, creepage distances, or safety parameters. Different drivers, power supplies, or safety characteristics require a separate review.

How much does LED lighting conformity assessment cost?

The cost is determined after classification. Factors include the number of applicable regulations, assessment form, model range diversity, testing volume, existing evidence, production audit logistics, and the complexity of drivers or adapters. No reliable fee can be calculated from the product name alone.

How long does the procedure take?

The time is assessed after classification. It depends on the product scope, model range, evidence file, testing volume, applicant arrangements, and production audit logistics. A fixed processing period should not be stated before these conditions are reviewed.

Where can an existing certificate or declaration be checked?

Certificates and declarations should be verified by registration number in the open public registry of FSIS Rosaccreditation. The check should confirm active legal status and covered models, after which the importer should compare the record with the manufacturer, applicant, driver, voltage, and actual shipment.

Free product check

Reestr Garant can review the product before the manufacturer commits to the wrong document type. Send the product details, HS or TN VED code, model list, electrical specifications, intended use, driver or adapter information, and available test reports.

The free check covers the product, the proposed HS or TN VED code, and the EAEU regulations that may apply. It identifies whether the next step should concern an EAC Certificate of Conformity, an EAC Declaration of Conformity, or another route determined after classification.

Send product details for a free check.

Send product details through the form below for a free product check. The practical starting point is a product-specific scope review before testing, document registration, or EAC marking.

Compare the EAC certificate and declaration routes before ordering tests.

Related requirements and services

• TR EAEU 037/2016 on hazardous substances in electrical equipment