TR CU 004/2011 and EAC conformity for low-voltage equipment

A manufacturer preparing to export powered equipment to Russia must first determine whether TR CU 004/2011 applies and which conformity assessment document the product requires. TR CU 004/2011 is the Technical Regulation of the Customs Union “On safety of low-voltage equipment.” It establishes mandatory safety requirements for electrical equipment within its defined scope across the EAEU.

The correct route may be an EAC Certificate of Conformity or an EAC Declaration of Conformity. The manufacturer cannot choose between them on commercial grounds. The product category, technical characteristics, Annex requirements, intended use, applicant structure, evidence, and any additional EAEU technical regulations must be checked together before the document is prepared.

“CU TR 004” is a search variant of TR CU 004/2011. The phrase “EAC TR CU 004” may refer generally to EAC conformity under the regulation, but it does not identify whether the product needs a certificate or a declaration.

Scope comes first.

Scope and exclusions

TR CU 004/2011 was adopted by Customs Union Commission Decision No. 768 of August 16, 2011. It applies to electrical equipment designed for use at a nominal rated voltage of 50 to 1,000 V AC inclusive and 75 to 1,500 V DC inclusive, provided that the equipment belongs to the regulated product scope and is not excluded.

The voltage range is an initial screening point, not a complete classification. A product must also be examined by its function, construction, intended use, form of supply, and relationship to other regulated equipment. A product that operates from an electrical supply is not automatically subject to one universal EAC certification route.

TR CU 004/2011 excludes several categories, including medical devices, equipment designed for explosive environments, and transport equipment. These exclusions do not mean that the product is unregulated. They mean that another regulation or regulatory framework may govern the product, so classification must continue under the rules applicable to that category.

Equipment designed exclusively for a DC supply below 75 V falls below the DC voltage threshold; all inputs and the supplied configuration must be checked. For such equipment, TR CU 020/2011 may apply only where the product is within its scope and is not an Annex 1 passive device. This distinction matters for low-voltage electronics, battery-powered products, controls, and accessories whose electrical characteristics may be described imprecisely in commercial materials.

Electrical components and sub-assemblies that are built into finished equipment and are not placed on the market as standalone goods are evaluated within the end-use product. They are not automatically treated as separate products requiring standalone certificates. The finished equipment and its safety characteristics determine the conformity route.

Product classification also depends on the way the equipment is supplied. A battery-powered tool or device may be within a different assessment situation when it is supplied with a mains charger or AC adapter. The supplied charging equipment must be included in the product review to determine whether the conformity evidence covers it or whether a separate assessment is required.

Products listed for mandatory certification

TR CU 004/2011 requires certification for product categories listed in its mandatory certification Annex. These categories include household electrical appliances, personal computers and connected devices, power supply units and chargers, power tools, lighting equipment, wiring accessories, and circuit breakers or residual-current devices.

The category name alone does not settle every case. The technical characteristics and exact product description must correspond to the Annex entry. A device marketed as an accessory may have a different regulatory status from a complete appliance, while a charger supplied with another product may need to be considered as part of the conformity evidence.

Low-voltage electrical equipment that falls within the voltage scope but is not listed in the mandatory certification Annex, such as some non-household industrial electrical equipment, is subject to declaration of conformity. For equipment subject to declaration, the manufacturer or importer has the right to choose certification instead of declaration. Products listed in the mandatory certification Annex cannot be moved to the declaration route by applicant preference.

Additional regulations and exclusions

TR CU 020/2011, “Electromagnetic compatibility of technical devices,” may apply in addition to TR CU 004/2011. Low-voltage equipment capable of generating electromagnetic disturbance or susceptible to electromagnetic noise must comply with TR CU 020/2011 when it falls within that regulation’s scope.

Passive technical equipment listed in Annex 1 is excluded from TR CU 020/2011. The EMC conclusion must therefore follow the device’s construction and the applicable regulations rather than its broad commercial description.

TR EAEU 037/2016, “On restriction of the use of hazardous substances in electrical and radio electronic products,” may also apply to electrical and radio-electronic equipment. It has been in force since March 1, 2018. Its conformity route is declaration, although Article 7(10) permits certification at the applicant’s choice. This route is separate from the TR CU 004/2011 assessment and should be checked independently.

TR CU 010/2011, “On safety of machinery,” does not automatically cover low-voltage electrical safety or EMC. Where machinery contains electrical circuits, the requirements under TR CU 004/2011 and TR CU 020/2011 must still be evaluated if their scopes apply.

TR CU 019/2011 concerns personal protective equipment. It is not the applicable regulation for ordinary low-voltage electrical equipment. It should be considered only when the product itself falls within the personal protective equipment scope.

Question	What must be verified	Primary source
Is TR CU 004/2011 applicable?	Voltage, function, construction, intended use, exclusions, and product category	TR CU 004/2011 and its Annexes
Is certification mandatory?	Whether the exact product is listed in the mandatory certification Annex	TR CU 004/2011 Annex requirements
Can EMC requirements also apply?	Whether the equipment generates or is susceptible to electromagnetic disturbance, and whether it is a passive device	TR CU 020/2011
Does hazardous-substance compliance apply?	Whether the equipment is electrical or radio-electronic equipment within the scope of TR EAEU 037/2016	TR EAEU 037/2016
Who may act as applicant?	The applicant’s EAEU registration and eligibility under the selected scheme	Applicable EAEU rules and scheme
Does the document cover the supplied product?	Model, manufacturer, ratings, configuration, and document status	EAEU unified registers and conformity document

Capture the exact electrical configuration before choosing samples

Ask the factory for a photo of the rating plate and a packing list for each version that will ship. For equipment supplied with an external adapter, identify both products and record the adapter input, adapter output and device input as separate fields. Add the exact plug, cable and adapter models supplied for the destination. The result should show which ratings belong to the finished equipment and which belong to the power supply.

Give the same configuration sheet to procurement, the lab and the conformity assessment participants. Keep a dated photograph of the sample and a copy of its component list. If the factory offers an alternate adapter or power board, record the substitute and ask the assessment participants to confirm which evidence covers it before committing to production. Compare any separate EMC question against the TR CU 020/2011 guidance.

Which route may apply

The form of conformity assessment under TR CU 004/2011 is mandated by the regulation’s Annex list and the product’s technical characteristics. A mandatory certification route cannot be replaced by declaration; certification may replace declaration where the applicable regulation permits it. The legally required form must be identified after the product has been classified.

An EAC Certificate of Conformity is issued by an accredited certification body included in the EAEU Unified Register. The certification body reviews the technical documentation and accredited laboratory test results under the applicable certification scheme. The certificate records the certified product, manufacturer, applicant, regulation, and other information required by the applicable EAEU form.

An EAC Declaration of Conformity is a separate conformity assessment document. The applicant adopts the declaration on the basis of compliance evidence and, in Russia, normally registers it through the Rosaccreditation service using an enhanced qualified electronic signature; the applicable national procedure must be checked. The applicant carries responsibility for the declaration under the applicable rules and must hold the supporting evidence required for the product and route.

A declaration is not a certificate, and a certificate is not a declaration. The two documents assign different responsibilities and use different assessment arrangements. A commercial page using the phrase “EAC TR CU 004” may describe either route, so the actual document type must be confirmed from the regulation and the product classification.

Certification schemes under TR CU 004/2011

Certification under TR CU 004/2011 is carried out under schemes 1c, 3c, and 4c. Scheme 1c concerns serial production, scheme 3c concerns a batch or consignment, and scheme 4c concerns a single item. Scheme 2c is not provided for under this regulation.

Under certification scheme 1c for serial production, an accredited testing laboratory tests representative product samples, and the certification body assesses the manufacturing facility. Certified serial production is subject to inspection control by the issuing certification body throughout the validity of the certificate.

An EAC Certificate of Conformity for serial production under scheme 1c is issued for a validity term of up to five years. A certificate for a batch under scheme 3c or a single item under scheme 4c has no expiration date established. These rules apply to the relevant certification situations and do not create a universal validity period for all EAC documents or all regulations.

Declaration schemes are identified only after the product, legal route, and applicable scheme requirements have been confirmed. The applicable declaration scheme may be expressed using the established Latin notation, such as 1d, 2d, 3d, 4d, or 6d, where that scheme is legally confirmed for the product. A declaration scheme is not a certificate scheme.

When can several models share one document?

Several models may be included in one conformity document only when they share the same manufacturer, intended function, and technical construction, and when testing covers the model variations. A model range cannot be grouped solely because the products have similar trade names or packaging.

Changes to safety-critical components require a new coverage review. These components include power boards, motors, batteries, rated wattage, and model designations. The responsible party must determine whether the existing test reports cover the modification or whether additional testing is required before release to the EAEU market.

EAEU applicant

A foreign manufacturer cannot file itself as the applicant when it is not registered as an eligible legal entity or individual entrepreneur in an EAEU member state. The applicant must be established in the EAEU where the relevant regulation and scheme require this status.

Generally, the applicant is an EAEU-registered legal entity or individual entrepreneur. Eligibility as a manufacturer, an authorised representative of the manufacturer, or a seller or importer depends on the particular regulation and scheme. An importer or seller is not eligible for every serial-production scheme, and the applicant role must be confirmed before the procedure begins.

For batch and single-item certification under schemes 3c and 4c, the applicant may be the manufacturer where the product is manufactured in the EAEU, an importer, or an authorised representative registered in an EAEU member state. For serial production under scheme 1c, the eligible applicant structure must be checked against the scheme requirements rather than assumed from the commercial relationship.

A foreign-owned entity registered in the EAEU should not be excluded merely because its owners are foreign. The relevant question is whether the entity is registered in the EAEU and eligible for the selected procedure. The unified forms provide separate particulars for the applicant and the manufacturer, so those roles must not be combined incorrectly.

The manufacturer supplies accurate product information, technical documents, samples, test data, operating documents, and production information. The applicant submits or adopts the document according to the selected route, maintains the required evidence, and participates in the registration process. The certification body performs certification activities where certification is required, while an accredited testing laboratory performs required tests.

Who can act as the applicant? The answer depends on the selected scheme and the manufacturer’s location. A foreign manufacturer normally works through an eligible EAEU legal entity or individual entrepreneur, such as an authorised representative or, where the scheme permits, an importer or seller. The parties should define their separate responsibilities before technical evidence is submitted.

Evidence and documents

The evidence file should identify the actual product and support the selected conformity route. The manufacturer should prepare a precise product description, model or series information, electrical ratings, intended use, technical specifications, and information about the construction that affects safety or electromagnetic performance.

Typical technical documents include circuit diagrams, drawings, descriptions of safety-relevant construction, a list of components affecting safety, manufacturing-site information where relevant, and details of production controls where the applicable scheme requires them. Product photographs and identification information help the applicant and assessment participants match the technical file to the supplied equipment.

The manufacturer should also prepare existing test reports, technical documents, standards used in design or testing, draft product labeling, rating-plate information, packaging details, and the proposed operating manual. These materials must describe the same product configuration. A discrepancy in model designation, rated power, manufacturer name, or intended use can prevent the evidence from supporting the document.

An accredited testing laboratory performs testing where the applicable certification or declaration procedure requires it. TR CU 004/2011 requires a listed accredited laboratory for certification. Factory in-house test reports and foreign laboratory reports do not automatically substitute for mandatory conformity testing in the EAEU.

European CE marks and EU Declarations of Conformity have no legal standing in the EAEU. They do not replace conformity with EAEU technical regulations. European technical material may be considered only where it is accepted as supporting evidence under the applicable EAEU procedure; it does not remove the requirement for the legally required EAC document or EAEU testing.

GOST references require the same care. A GOST standard is not automatically mandatory because it appears in a technical file or was used during design. Its relevance depends on the legal basis that incorporates or recognizes it for the applicable requirement. The responsible party should verify the applicable official lists and the product-specific legal route before treating a standard as required.

Documents for a conformity review

• Product name, model, type, or series designation.
• Manufacturer name and manufacturing-site information.
• Electrical ratings, power supply details, and technical specifications.
• Intended use, operating environment, and user category.
• Circuit diagrams, drawings, and safety-relevant construction descriptions.
• Information about safety-critical components and possible model variations.
• Test reports and other compliance evidence required by the selected procedure.
• Installation, operation, maintenance, storage, transportation, and safety information where applicable.
• Draft rating plate, product labeling, packaging, and shipping information.
• Operating manual and any other documents supplied with the equipment.

The final document set is determined after classification. A product that requires certification may need representative samples, production information, and a manufacturing facility assessment, while a declaration route uses the evidence required by the applicable declaration scheme. Preparing a universal file before the route is known creates avoidable work.

Process

1. Define the product. The manufacturer records the exact function, model or series, electrical ratings, intended use, construction, supplied accessories, and operating environment. The product description should distinguish a finished product from a component or sub-assembly built into another product.
2. Check the scope. The manufacturer, applicant, or compliance specialist compares the product with TR CU 004/2011, its exclusions, voltage ranges, and Annex categories. The same review considers TR CU 020/2011, TR EAEU 037/2016, machinery requirements, medical-device requirements, PPE requirements, and other regulations that may apply.
3. Determine the conformity form. The responsible party identifies whether the product is listed for mandatory certification or falls within the declaration route. The party then confirms the applicable scheme. Certification schemes 1c, 3c, and 4c are used under TR CU 004/2011 where their respective conditions apply; declaration schemes are selected only after the declaration route is confirmed.
4. Confirm the applicant. The foreign manufacturer identifies the eligible EAEU legal entity or individual entrepreneur. The parties record whether the applicant is an authorised representative, importer, seller, or another eligible party under the selected scheme.
5. Prepare the evidence file. The manufacturer supplies the technical description, drawings, ratings, component information, test evidence, production information, operating manual, and labeling materials required by the route. The applicant checks that the evidence covers the actual model and configuration.
6. Complete testing and assessment. The accredited testing laboratory performs required testing, and the certification body performs certification activities where certification is mandatory or selected. Under scheme 1c, the accredited testing laboratory tests representative samples and the certification body assesses the manufacturing facility. The precise activities depend on the product and scheme.
7. Issue or register the document. The accredited certification body issues an EAC Certificate of Conformity when certification is required and the assessment is completed. Under the declaration route, in Russia, the applicant normally adopts and registers the declaration through the Rosaccreditation service using an enhanced qualified electronic signature.
8. Check the product information. The manufacturer and applicant compare the conformity document, test report, operating manual, rating plate, packaging, and commercial shipping invoice. Product name, model, manufacturer details, and technical parameters must be fully consistent.
9. Apply the EAC mark. The EAC mark may be affixed only after the product has completed mandatory conformity assessment under all applicable technical regulations. The responsible party checks the mark, product labeling, packaging, operating documents, and product identity before market placement.
10. Keep records and monitor changes. The manufacturer and applicant retain the evidence required by the applicable rules. They also review changes to safety-critical components, model designations, manufacturing sites, ownership, technical regulations, and recognized standards before releasing modified equipment.

How long does the process take? Timing is assessed after classification because the route determines the evidence, testing, production review, applicant, and registration actions. A serial-production certification procedure may require more activities than a batch or single-item procedure, while a declaration requires the evidence and registration steps prescribed for that product.

Marking and information

The EAC mark, also called the Eurasian Conformity mark, communicates that the product has completed the applicable EAEU conformity procedure. It is not a substitute for an EAC Certificate of Conformity or an EAC Declaration of Conformity, and it does not establish conformity by itself.

The unified EAC mark may be affixed to the product, packaging, and documentation only after the product has completed mandatory conformity assessment under all applicable technical regulations. The responsible party must verify the applicable requirements for the mark’s placement, visibility, and durability before applying it.

The mark must not be placed on equipment before the correct document exists. It must also not be used for a model, modification, charger, or configuration that is outside the document’s coverage. A certificate or declaration covering one model does not automatically cover a modified product.

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 this. The language rule cited here concerns operating documents. It should not be expanded into an unsupported claim that the same rule independently governs every element of product labeling.

The TR 004 user manual

The search phrase “TR 004 user manual” usually refers to the operating manual prepared for equipment assessed under TR CU 004/2011. The manual is part of the product evidence and instructions package, not an afterthought prepared after the conformity document has been issued.

The operating manual should accurately explain the product’s intended use, safe installation, commissioning, operation, maintenance, storage, transportation, and disposal where the applicable requirements call for that information. It should identify relevant limitations and warnings and should correspond to the actual model, ratings, accessories, and safety features.

The exact content depends on TR CU 004/2011, the product category, any other applicable EAEU technical regulations, and the documentation rules for the equipment. A universal manual template cannot establish compliance for every low-voltage product. The manufacturer should check the final content against the classified product and the selected route.

Where machinery and equipment also fall under TR CU 010/2011, operating documentation is part of the required equipment package. TR CU 010/2011 has applied since February 15, 2013, and includes operating documentation requirements for machinery and equipment within its scope. This does not mean that every product assessed under TR CU 004/2011 is machinery.

Medical devices require a different documentation analysis. EEC Council Decision No. 27 of February 12, 2016 approved general safety and effectiveness requirements for medical devices, including requirements for labeling and operational documentation. A manufacturer must classify a medical product under the applicable medical-device framework rather than copy an electrical-equipment manual structure.

Consistency review

The manufacturer should compare the manual with the nameplate, technical file, test reports, certificate or declaration, packaging, and commercial shipping invoice. Model designation, manufacturer name, electrical ratings, warnings, intended use, and supplied accessories should not contradict one another.

Translation into Russian alone does not make an operating manual compliant. The translation must accurately reflect the approved product information and the applicable documentation requirements. Any state-language requirement applicable in the destination EAEU member state must also be considered before the product is released.

Timing and price drivers

No reliable processing time can be stated before classification. Timing is assessed after the product category, conformity form, scheme, applicant, testing needs, production review, and document status are established. The relevant period may also depend on whether the manufacturer provides a complete and consistent evidence file.

The price is determined after the same technical review. Relevant factors include the product category, number of models, whether the product is serial production, a batch, or a single item, the required conformity form, laboratory testing, sample quantity, production condition analysis, manufacturing-site assessment, inspection control, additional applicable regulations, document preparation, translation, and the complexity of model variations.

Certification scheme 1c may involve representative-sample testing, a manufacturing facility assessment, and later inspection control. Schemes 3c and 4c concern different supply situations. A declaration route has its own evidence and registration requirements. These differences affect the work required, so a fixed price or period cannot be stated responsibly before the route is known.

Multiple models may reduce repeated work only when the models meet the legal and technical conditions for one document. If power boards, motors, batteries, rated wattage, or model designations differ, additional coverage analysis or testing may be necessary.

Typical classification mistakes

The most serious avoidable error is choosing the conformity form before classifying the product. An exporter sees the phrase “low-voltage equipment,” assumes that every product requires an EAC Certificate of Conformity, and starts a certification file without checking the Annex, exclusions, declaration route, or additional regulations.

This approach can produce an incorrect application, inconsistent evidence, or a document that does not cover the product as supplied. The same problem appears in the opposite direction when an applicant prepares a declaration for a product listed in the mandatory certification Annex, where declaration is not permitted under TR CU 004/2011.

A second mistake is treating every electrical accessory as a standalone product. Components built into finished equipment and not placed on the market independently are evaluated within the end-use product. The assessment changes when the same component is sold as a standalone good.

A third mistake is treating CE documents, ISO certificates, internal test reports, or a foreign laboratory report as substitutes for the required EAEU evidence. They may provide technical information where the applicable procedure accepts it, but they do not automatically establish conformity in Russia or another EAEU member state.

A fourth mistake is copying one document set across different product categories. Machinery, medical devices, equipment for explosive environments, transport equipment, PPE, radio-electronic products, and ordinary low-voltage equipment may follow different rules. A document that is suitable for one category cannot be assumed to cover another.

The corrective checklist should record:

• The exact product function and intended use.
• The model, modification, and supplied accessories.
• The voltage and technical characteristics relevant to scope.
• The applicable technical regulation or regulations.
• The legal reason for the selected certificate or declaration route.
• The certification or declaration scheme confirmed for the product.
• The eligible EAEU applicant and each party’s responsibility.
• The evidence supporting the classification and conformity conclusion.
• The manual, rating plate, packaging, and label versions reviewed.
• The register entry or certificate details checked after completion.

This review reduces avoidable rework, but it cannot guarantee a particular assessment result. The result depends on the product, evidence, testing, and requirements that apply after classification.

FAQ

What is TR CU 004/2011?

TR CU 004/2011 is the Technical Regulation of the Customs Union “On safety of low-voltage equipment.” It establishes mandatory safety requirements and conformity assessment rules for electrical equipment within its scope before the equipment is placed on the EAEU market. It applies to equipment designed for 50 to 1,000 V AC inclusive and 75 to 1,500 V DC inclusive, subject to exclusions and product classification.

What does “CU TR 004” mean?

“CU TR 004” is a search and wording variant for TR CU 004/2011. The established designation is TR CU 004/2011. The abbreviation does not show whether the product requires an EAC Certificate of Conformity or an EAC Declaration of Conformity. That decision follows the product category, technical characteristics, Annex requirements, and applicable scheme.

Does every low-voltage product need an EAC Certificate of Conformity?

No. Products listed in the mandatory certification Annex require certification, while low-voltage equipment within the voltage scope but outside that Annex is subject to declaration of conformity. The manufacturer or importer may choose certification instead of declaration where the declaration route applies, but a product listed for mandatory certification cannot be declared under TR CU 004/2011.

What is the difference between an EAC certificate and an EAC declaration?

An EAC Certificate of Conformity is issued by an accredited certification body included in the EAEU Unified Register after the required assessment and testing. An EAC Declaration of Conformity is adopted by the applicant on the basis of compliance evidence and registered directly by the applicant in the Rosaccreditation register using an enhanced qualified electronic signature. One document cannot be described as the other.

Can a foreign manufacturer apply directly?

A foreign manufacturer that is not registered as an eligible EAEU legal entity or individual entrepreneur cannot itself act as the applicant under the relevant schemes. An eligible EAEU authorised representative or, where the scheme permits, an importer or seller may apply. Eligibility depends on the regulation and scheme, and the applicant and manufacturer must be shown as separate parties where the forms require it.

Can TR CU 020/2011 apply together with TR CU 004/2011?

Yes, it may apply where the low-voltage equipment can generate electromagnetic disturbance or is susceptible to electromagnetic noise and falls within the EMC scope. Passive technical equipment listed in Annex 1 is excluded from TR CU 020/2011; other applicable regulations must be checked separately.

What should a TR 004 user manual contain?

The operating manual should provide accurate instructions and safety information appropriate to the product and applicable rules, including information about intended use, installation, operation, maintenance, storage, transportation, limitations, and warnings where required. Its exact content depends on the product category and other applicable EAEU regulations. The manual must be consistent with the equipment, technical file, rating plate, packaging, and conformity document.

Can CE marking replace EAC conformity?

No. European CE marks and EU Declarations of Conformity have no legal standing in the EAEU and do not replace conformity with EAEU technical regulations. European technical documents may be considered only as supporting evidence where the applicable EAEU procedure accepts them. The required EAC document and EAEU assessment remain necessary.

How can an EAC document be checked?

The product information should be compared with the relevant EAEU unified register record and, where applicable, the Rosaccreditation public register. Check the product name, model, manufacturer, applicant, regulation, status, and technical characteristics. A scanned document, supplier statement, or search-engine result alone does not prove that the record covers the equipment being imported.

Free applicability check

Reestr Garant reviews the product, HS/TN VED code, intended use, electrical characteristics, model structure, and potentially applicable EAEU technical regulations before the conformity route is selected. The check identifies whether TR CU 004/2011 may apply, whether TR CU 020/2011 or TR EAEU 037/2016 must also be considered, and whether the product is directed toward certification or declaration.

The review also considers the EAEU applicant, the documents to prepare, the need for accredited laboratory evidence, the operating manual, product labeling, model grouping, and register verification. It does not replace the legally required assessment and does not promise a certificate, declaration, registration result, or market acceptance before the product is checked.

Request a free applicability check for the product, HS/TN VED code, and applicable regulations before selecting an EAC document.

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