Under TR CU 017/2011, a set of adult bed linen requires certification, while table linen follows a declaration route. Both may be woven from the same cotton. The finished article, its intended use and the relevant product group determine the route. Start there before using a supplier's document or booking a laboratory.
Identify the finished article and intended user
TR CU 017/2011 covers light industry goods placed on the EAEU market, including many adult garments, footwear, fabrics and finished household textiles. Check the product list and the exclusions in Article 1. Articles intended for children and adolescents, and articles sold as personal protective equipment, require a scope review under their own rules. A uniform with a company logo can be ordinary clothing. A garment sold to protect workers against a specified hazard requires a PPE assessment.
Use the garment's actual construction and intended wearing position when checking layer. Underwear, a lined jacket and a coat worn over other garments are different use cases. A marketplace's category may put several of these products together. Record the intended wearer, material and type for each model and compare that information with the technical description and proposed consumer label.
When certification is required
The amended Article 11 names underwear, corsetry, swimwear, bed linen and first-layer hosiery as groups subject to certification. The certification body reviews the application and arranges conformity assessment under the appropriate scheme. Testing for certification is carried out by an accredited laboratory. The amended rules provide serial and batch certification schemes, with batch evidence tied to the actual consignment.
For example, a supplier may sell adult swimwear and a beach cover-up under a single range name. Identify the swimwear and the cover-up separately. Check the latter's garment type and layer before deciding what evidence and document it needs. Link each invoice model to the assessment result that covers it.
Which categories use a declaration
The listed schemes involve accredited laboratory evidence. Check the exact wording of the group before choosing a scheme.
For serial production, the applicant is an eligible manufacturer established in an EAEU member state or a locally established entity authorised by the manufacturer. For a batch, an eligible seller or importer may also apply. If the commercial plan changes from a single order to regular supply, review the applicant and scheme before accepting new orders under the batch paperwork.
Give the laboratory a usable sample file
- List model numbers, type, intended user and garment layer where relevant. Include photographs that show construction, seams, lining, sole or other distinguishing features.
- Provide the actual composition of each relevant material, including lining and filling where present. Flag changes in dyes, coatings and finishes before the sample plan is agreed.
- Identify each factory, and match each sample with its model, colour and material specification. Ask the assessment participants to document the models the selected samples represent.
- Give the applicant draft consumer labels, available test reports and the intended form of supply. Attach the consignment evidence where a batch route applies.
Check the consumer label and the final record
Article 9 contains general and product-specific marking requirements. Match the name, manufacturer, size where applicable and product identification to the documents. For clothing and textiles, check how the fibre composition and care information are stated. Footwear has separate material labelling requirements. Review the wording and language for the intended destination before printing production labels. Add the EAC mark after completion of the applicable conformity procedures.
On a repeat order, compare the factory, materials and models against the evidence file. A supplier may retain its style number after replacing a lining or manufacturing site. Send the change to the applicant or certification body before assuming the existing documents cover the new supply.
Questions from importers
Do bed sheets and tablecloths follow the same route?
No. The amended Article 11 lists bed linen for certification and table linen among the declaration groups.
Does every garment touching the skin need certification?
Use the listed product group. The certification list identifies specific products such as underwear, swimwear and first-layer hosiery. Check the actual garment against that list.
Can the importer use a factory's composition report?
Use it to identify materials and plan evidence. The chosen scheme determines which product tests and laboratory evidence the assessment requires.
Can one document cover several colours and sizes?
Compare the model list, materials and production sites with the assessment scope. Ask the assessment participants how the evidence covers differences in construction, dyes or finishes.
For an initial review, prepare the model list, intended users, production sites, material specifications and label drafts. State whether the order is a batch or the start of regular supply.
Compare the certificate and declaration routes and check what evidence applies to your product.