How to comply with TR CU 020/2011 for products entering the EAEU

TR CU 020/2011, “Electromagnetic compatibility of technical devices,” applies to technical equipment released into circulation across EAEU member states when it can create electromagnetic interference or its operation can be affected by external electromagnetic interference. Its practical purpose is to assess whether covered equipment emits unacceptable interference and can operate as intended in its electromagnetic environment.

The product must be classified before the conformity document is selected.

Depending on the product and the applicable route, the result may be an EAC Certificate of Conformity or an EAC Declaration of Conformity. These documents assign different responsibilities. An EAC certificate is issued by an accredited certification body after the required evaluation. An EAC declaration is adopted by the applicant and registered under the applicable rules. The applicant is responsible for the supporting evidence under the applicable rules. A manufacturer without an eligible EAEU-registered legal entity or individual entrepreneur cannot act as applicant directly; the applicant must meet the eligibility rules for the selected scheme and generally must be an EAEU-registered legal entity or individual entrepreneur.

Scope and exclusions

TR CU 020/2011 applies to technical equipment that can generate electromagnetic interference or that can be vulnerable to electromagnetic disturbances. The assessment therefore concerns the product as it is supplied and used for its intended purpose, rather than the mere presence of a circuit board, processor, power supply, or communications interface.

Electromagnetic compatibility has two practical sides. Equipment must keep its generated electromagnetic emissions within the applicable limits, and it must have sufficient immunity or resistance to disturbances expected during operation. Laboratory EMC testing evaluates these two properties, while the legal route depends on the product provisions, the applicable scheme, and the evidence required under the regulation.

TR CU 020/2011 was adopted by Customs Union Commission Decision No. 879 of December 9, 2011, and entered into legal force on February 15, 2013. It remains relevant within the EAEU conformity framework. Some businesses search for “TR CU 020 English” when they need an English explanation, while “EAC TP TC 020” and “TR CU 20” are common alternative search expressions. These terms do not describe separate regulations. Formal compliance documents should use the applicable legal designation and register wording.

Passive technical equipment listed in Annex 1 is expressly excluded from the scope of TR CU 020/2011. Examples include passive cables, simple resistive appliances without automatic switches, passive headphones, and passive antennas. Galvanic cells, electric batteries, and battery-powered equipment without active electronic circuits are also excluded. A battery-powered device that contains a charge controller or voltage converter remains within the scope review because those active circuits affect its regulatory classification.

The exclusion for components also depends on how the product is supplied and used. Components designed solely for incorporation by a manufacturer into other technical equipment, and not intended for independent end-user operation, are not independent objects of conformity assessment under TR CU 020/2011. The same conclusion should not be extended automatically to a module or component that is marketed as a functional product for independent use.

Finished equipment and microcontrollers

A microcontroller installed inside a finished device is not automatically a separate object requiring its own TR CU 020/2011 document. The relevant conformity assessment normally concerns the finished technical device that is placed on the EAEU market, with its intended use, operating modes, interfaces, and supplied configuration.

What happens when a microcontroller is sold separately? The answer depends on the form in which it is supplied and marketed. A part intended only for incorporation into another manufacturer’s equipment may fall within the component exclusion, while a module or functional device intended for independent operation requires a separate classification review. The product description must therefore distinguish an internal component from an independently marketed device.

The use of a microcontroller in medical equipment does not by itself create a separate medical-device route under TR CU 020/2011. The finished medical product and the rules that actually govern that product must be reviewed. TR EAEU 027/2012 should not be presented as a general regulation on medical devices.

Products that may be subject to other EAEU rules

Electromagnetic compatibility is one part of market access. A product may also fall under TR CU 004/2011, “On safety of low-voltage equipment,” or TR EAEU 037/2016, “On restriction of the use of hazardous substances in electrical and radio electronic products.” Other EAEU technical regulations may apply according to the product’s function, construction, sector, and intended use.

Equipment in these voltage ranges should be checked against TR CU 004/2011, including its scope and exclusions, alongside any applicable EMC requirements. The voltage condition does not eliminate the need to review electromagnetic compatibility, and compliance under one regulation does not automatically satisfy the other.

TR EAEU 037/2016 addresses restricted substances in electrical and radio electronic products. It has been in force since March 1, 2018. A product within its scope must be reviewed separately, because EMC test evidence does not prove compliance with substance restrictions. TR EAEU 037/2016 uses a declaration route, while its Article 7(10) permits certification at the applicant’s choice.

Residual-current devices illustrate why classification must precede document selection. These devices are expressly included in the mandatory certification list for TR CU 004/2011, so that regulation does not leave a free choice between certification and declaration. Separately, residual-current devices with electronic control fall within the relevant certification scope connected with TR CU 020/2011. The exact route still depends on the current applicable lists and the product’s design.

Which route may apply

TR CU 020/2011 provides different conformity assessment routes. Mandatory EAC certification applies to technical equipment listed in Annex 3, which includes household electrical appliances, personal computers and cash registers, PC peripherals, power hand tools, and electronic musical instruments. Technical equipment within the regulation’s scope but outside Annex 3 is subject to conformity assessment in the form of an EAC declaration of conformity.

The legal form cannot be chosen from the product name alone. The applicant must compare the finished product with the regulation’s scope, Annex 3, the current unified product list, the applicable customs commodity list, and the relevant conformity assessment provisions. A manufacturer should record the basis for the selected form because scope, obligation, and document type are separate questions.

Question	What must be verified	Primary source
Does TR CU 020/2011 apply?	Whether the finished equipment can create electromagnetic interference or is vulnerable to external electromagnetic interference, and whether an exclusion applies.	TR CU 020/2011, including Annex 1
Is mandatory certification required?	Whether the equipment is listed in Annex 3 and whether the current product and conformity assessment lists confirm that route.	TR CU 020/2011, Annex 3, and the applicable EAEU lists
Which declaration or certification scheme applies?	The product type, production model, batch or single-item status, evidence, and scheme-specific applicant eligibility.	TR CU 020/2011 and the applicable EAEU conformity assessment rules
Are other regulations relevant?	Voltage range, product function, electrical and radio-electronic construction, and any other characteristics that trigger a separate review.	TR CU 004/2011, TR EAEU 037/2016, and other applicable EAEU regulations
Is the document recorded correctly?	Manufacturer, applicant, product description, models, status, and registration record in the unified register or its national part.	Unified EAEU registers and the Russian accreditation system

EAC certification

An EAC Certificate of Conformity is issued by an accredited certification body after the body performs the evaluation required by the applicable scheme. The procedure may involve sample testing, production condition analysis, review of technical documentation, and inspection control, depending on the selected route. The manufacturer does not create the certificate itself, and a laboratory report is not an EAC certificate.

Conformity certification under TR CU 020/2011 is carried out only under schemes 1c for serial production, 3c for a batch, and 4c for a single item. Scheme 1c includes sample testing in an accredited testing laboratory, production condition analysis, and periodic inspection control during the certificate term. Scheme selection must be supported by the product and its supply model rather than by a general preference for certification.

Where applicable standards are not applied or are absent, the conformity route and supporting evidence are determined after classification and review of the applicable legal and technical requirements.

EAC declaration

An EAC Declaration of Conformity is adopted and registered by the responsible applicant. The applicant is responsible under the applicable rules for the supporting evidence and the accuracy of submitted information. The certification body does not issue an EAC declaration as though it were an EAC Certificate of Conformity, although certification-body registration may occur in specified cases under the registration rules.

Declaration schemes under TR CU 020/2011 are 1d, 3d, and 6d for serial production, and 2d and 4d for a batch or single item. Schemes 1d and 2d allow the applicant’s own evidence. Schemes 3d, 4d, and 6d require testing in an accredited testing laboratory, while scheme 6d also requires a certified quality management system. The evidence and applicant must therefore be reviewed before a declaration scheme is selected.

An applicant for equipment subject to declaration may voluntarily choose certification instead of declaration when the selected certification scheme is applicable to the product. This option does not allow the applicant to ignore the regulation, use an unsuitable scheme, or replace required EAEU evidence with a foreign document.

Certificate and declaration terms

An EAC certificate or declaration for serial production is issued for a term of up to five years. A certificate or declaration for a batch or single item has no expiration term established. The applicable term and document scope must be recorded accurately, because a batch document and a serial-production document describe different supply situations.

The EAC certificate and EAC declaration are recorded in the unified register and its national parts. In Russia, the register and electronic service operate through the accreditation system. The applicant normally registers a declaration using the electronic service, while registration by a certification body applies in specified cases. A scanned document or commercial database entry should not be treated as the only verification source.

Agree the EMC test setup with the lab before dispatching samples

Give the lab a setup sheet with the hardware revision, software build, power supply, cable types and lengths, ports in use and intended installation. List the operating modes customers can actually use, such as transmitting, charging, switching a load or running several interfaces together. For each mode, explain how the lab can activate it and observe whether the equipment continues to perform as intended.

Keep photos of the setup and record any mode the lab did not exercise. If the firmware, radio module, power supply or cable arrangement changes before production, compare it with the tested setup and ask the lab or assessment body whether the report still supports the new configuration. Use the EEC's regulation page to locate the applicable lists and amendments. EEC standards and amendments for TR CU 020/2011.

EAEU applicant

A manufacturer without an eligible EAEU-registered legal entity or individual entrepreneur cannot act as applicant directly.. The applicant generally must be an EAEU-registered legal entity or individual entrepreneur, but eligibility depends on the selected regulation and scheme. The eligible party may be the manufacturer, an authorised representative of the manufacturer, or a seller or importer where the specific procedure permits that role.

Who can act as the EAEU applicant? The answer must be taken from the selected scheme, not from the manufacturer’s location alone. Sellers and importers are not eligible for every serial-production scheme. An authorised representative of the manufacturer must have the authority and information needed to support the procedure, while the manufacturer remains the party responsible for the product’s design and production information.

The applicant’s identity affects the conformity document, register record, evidence file, and later communication with authorities. The applicant should be able to identify the manufacturer, models, modifications, production site, intended use, and technical evidence, because an incomplete relationship between the manufacturer and applicant can prevent reliable document registration.

The importer is not automatically the holder of an EAC document. An importer may be eligible under a particular scheme, but that status must be confirmed before the application is prepared. The commercial relationship with the foreign manufacturer should also provide a clear basis for the applicant’s authority to use the technical information and represent the product in the EAEU procedure.

Evidence and documents

The applicant must prepare a product file that identifies the actual equipment placed on the EAEU market. At the initiation stage, the required information includes applicant and manufacturer details, a technical description, an operating manual, circuit diagrams, label photographs, and supply contract or shipping documents for batch imports.

• Manufacturer name and address information.
• Applicant information and evidence of the applicant’s relationship with the manufacturer.
• Product name, model numbers, modifications, and product-family information.
• Technical description and specifications.
• Operating manual and installation information.
• Circuit diagrams or functional descriptions where relevant.
• Information about power supplies, cables, interface boards, and active radio modules.
• Label photographs and proposed product identification.
• Supply contract or shipping documents for a batch import.
• Existing technical evidence and test reports that can be considered under the selected EAEU procedure.

This is a practical starting set rather than a universal legally complete checklist. The final evidence file depends on whether the route is certification or declaration, whether the product is serial production, a batch, or a single item, which scheme applies, and whether other EAEU technical regulations must be addressed at the same time.

EMC test evidence

EMC testing must represent the product in its real operational configuration. Samples must be submitted with power supplies, cables, interface boards, and active radio modules that match the declared model and operating modes. Testing an incomplete prototype can create a mismatch between the evidence and the equipment identified in the EAC document.

An accredited testing laboratory evaluates the electromagnetic emission levels generated by the device and the device’s immunity or susceptibility to external electromagnetic disturbances. The test report should identify the tested manufacturer, model, configuration, operating conditions, and relevant test basis so that the applicant and certification body can connect the report to the product covered by the procedure.

Foreign technical evidence may be useful, but its acceptance depends on the applicable EAEU procedure and the body or applicant responsible for conformity assessment. CE marking, an EU EMC declaration, an FCC document, a CB document, or a foreign restricted-substances document does not automatically establish EAEU conformity and does not by itself permit the EAC mark.

GOST standards may be relevant when they appear in an applicable official standards list or are otherwise accepted as a means of demonstrating compliance under the relevant rules. A GOST standard should not be treated as mandatory merely because it is technically useful. ISO certification also does not replace an EAC certificate or an EAC declaration.

Process

The process starts with the finished product, not with a request for a preferred document. The applicant and manufacturer should first establish what is being placed on the EAEU market, how it operates, who will use it, and whether it is supplied as a complete device, module, component, batch, or serial-production product.

Step 1: Define the product

Record the commercial name, model numbers, modifications, intended use, operating environment, power characteristics, interfaces, supplied accessories, and active electronic functions. Identify whether the product contains charge controllers, voltage converters, radio modules, or other circuits that affect its classification.

Step 2: Check scope and exclusions

Compare the technical device with TR CU 020/2011 and Annex 1. Confirm whether it can create electromagnetic interference or is vulnerable to external interference, and check whether it is passive equipment, a battery-powered product without active electronic circuits, or a component designed solely for incorporation into other equipment.

Step 3: Review other regulations

Check whether the product also requires assessment under TR CU 004/2011 because of its voltage range, and review TR EAEU 037/2016 for restricted substances in electrical and radio electronic products. The same product may require separate evidence or documents under more than one regulation.

Step 4: Check official lists

Compare the product with the current unified EAEU product list, the applicable conformity assessment lists, Annex 3 of TR CU 020/2011, and relevant customs commodity entries. A broad customs code or marketing name is not enough to establish the route. The current official lists and legal acts should control the decision.

Step 5: Select the form and scheme

Determine whether the product requires an EAC Certificate of Conformity, an EAC Declaration of Conformity, or no mandatory document under that particular regulation. If certification applies, the available schemes are 1c, 3c, and 4c. If declaration applies, the relevant schemes are 1d, 2d, 3d, 4d, and 6d, subject to the product and scheme conditions.

Step 6: Identify the applicant

Confirm the EAEU-registered legal entity or individual entrepreneur that is eligible under the selected scheme. Record whether the applicant acts as the authorised representative of the manufacturer, seller, importer, or another permitted party. The foreign manufacturer should provide the information and authority required for the applicant to support the procedure.

Step 7: Prepare samples and evidence

Compile the technical documentation and submit representative product samples in the complete operational configuration when testing is required. Confirm that the sample, test report, product description, and intended operating modes refer to the same model and modifications.

Step 8: Complete certification or declaration

For certification, the accredited certification body performs the evaluation required by the selected scheme and issues the EAC certificate after a positive conformity decision. For declaration, the applicant adopts and registers the EAC declaration under the applicable rules and assumes responsibility for the supporting evidence.

Step 9: Verify the register entry

Check the unified register and its national parts for the document status, applicant, manufacturer, product description, models, and covered modifications. In Russia, the relevant electronic service is administered through the accreditation system. The register entry should correspond to the product that will actually be shipped.

Step 10: Mark the product and retain records

Apply the EAC mark after all applicable assessments are complete and the required certificate has been issued or the declaration has been registered. The applicant keeps the declaration and supporting evidence for the period set by EEC Council Decision No. 44 and the applicable regulation, at least 10 years, and must provide them to authorities upon request.

Marking and information

The EAC mark, also called the Eurasian Conformity mark, indicates that the product has passed the applicable EAEU conformity assessment and may be released under the relevant rules. It does not replace the EAC Certificate of Conformity, the EAC Declaration of Conformity, the technical documentation, or the registration record.

EAC is applied before release after all applicable assessments are complete. The 5-mm minimum for the mark is established by Customs Union Commission Decision No. 711 of July 15, 2011, on the EAC mark regulation and graphics, rather than by TR CU 020/2011 itself.

Article 4 of TR CU 020/2011 prescribes marking content and placement. Operating documents must be in Russian and also in the state language or languages of the EAEU member state where its legislation requires this. The stated language rule concerns operating documents, so it should not be presented independently as a rule governing every element of product labelling.

The responsible party should verify whether the EAC mark is required, where it may be placed, which product information must accompany it, and whether the document details match the exact model, brand, modification, and manufacturer. A single document should not be assumed to cover every variant or manufacturing location without checking its recorded scope.

Timing and price drivers

Processing timing is assessed after classification. It depends on the product scope, document form, selected scheme, sample requirements, laboratory work, production condition analysis, applicant eligibility, and any additional EAEU regulations that apply. A reliable timing statement cannot be made before these conditions are known.

For serial production, an EAC certificate or declaration may be issued for a term of up to five years. For a batch or single item, no expiration term is established. These are document-term rules, not promises about the time required to complete the conformity procedure.

Cost depends on the work required for the particular product. Relevant factors include:

• Whether the route requires an EAC certificate or an EAC declaration.
• Whether the product is serial production, a batch, or a single item.
• The selected certification or declaration scheme.
• The number of models and modifications.
• The scope of EMC testing.
• The number and configuration of product samples.
• Whether production condition analysis or inspection control is required.
• Whether other technical regulations must be assessed.
• The completeness and quality of the technical documentation and existing evidence.

A cost review should follow the product classification and scheme decision. Quoting a document type before checking the product can produce the wrong scope, incomplete testing, or an applicant structure that does not meet the selected procedure.

Typical classification mistakes

Treating every electronic product as covered

The presence of electronics does not decide the route. A finished device must be compared with the scope and exclusions of TR CU 020/2011, while passive equipment, certain batteries, and components designed solely for incorporation may have a different position.

Requesting a certificate before checking Annex 3

Annex 3 identifies the equipment subject to mandatory certification under TR CU 020/2011. Equipment within scope but outside that list follows the declaration route unless another applicable rule changes the analysis. Certification may be chosen voluntarily only when the selected certification scheme is applicable.

Using CE documents as an EAEU result

CE marking and EU EMC documents may provide technical information, but they do not replace EAEU conformity assessment. The manufacturer must complete the applicable EAEU procedure, record the correct applicant, and satisfy the EAC marking rules before release.

Assessing a microcontroller instead of the finished device

A microcontroller used only inside finished equipment is not automatically an independent TR CU 020/2011 object. The product must be assessed in the form in which it is placed on the market. A separately marketed module requires its own classification review.

Using an outdated list or register record

Product lists and register information must be checked against current official EAEU sources. An earlier commercial table, an old document scan, or an entry that does not identify the actual model cannot establish the current route by itself.

Calling a test report an EAC document

A test report records laboratory evidence. It is not an EAC Certificate of Conformity or an EAC Declaration of Conformity. The final EAEU document must be issued or registered through the applicable procedure.

Testing an incomplete configuration

EMC samples must include the power supplies, cables, interface boards, and active radio modules that match the declared model and operating modes. A report for a materially different configuration may not support the product placed on the market.

Assuming one document covers every modification

The manufacturer and applicant must compare the document scope with every model, brand, modification, production site, and operating configuration intended for the EAEU market. Changes to design, components, software, production location, or model designation may require a new review.

Applying the EAC mark too early

The EAC mark follows the completed applicable conformity procedure. It cannot replace testing, certification, declaration registration, or verification of the unified register record.

FAQ

Is TR CU 020/2011 the same as EAC TP TC 020?

EAC TP TC 020 is a common search and naming variant for TR CU 020/2011, the EAEU regulation on electromagnetic compatibility of technical devices. It is not a separate regulation. Formal compliance work should use the applicable legal designation and the wording recorded in the relevant EAEU document or register.

What does TR CU 20 mean?

TR CU 20 is a shortened search expression for TR CU 020/2011. It should not be treated as a separate technical regulation. The conformity decision must rely on the full regulation, its scope and exclusions, the applicable product lists, and the selected assessment scheme.

Does every electronic product require an EAC certificate under TR CU 020/2011?

No. The product must first be compared with the regulation’s scope and exclusions. Mandatory certification applies to technical equipment listed in Annex 3. Other equipment within scope follows the EAC declaration route under the applicable rules, although voluntary certification may be available when a suitable certification scheme exists.

Can a CE document replace TR CU 020/2011 conformity assessment?

No. CE marking and EU conformity documents do not automatically replace EAEU conformity assessment and do not independently permit the EAC mark. They may be considered as technical information, but the applicant must complete the applicable EAEU procedure and provide the evidence required by that procedure.

Does a microcontroller need its own TR CU 020/2011 document?

A microcontroller designed only for incorporation into finished equipment and not intended for independent end-user operation is not automatically a separate conformity assessment object under TR CU 020/2011. The finished device is generally the relevant product. A separately marketed functional module requires a separate classification review.

Is an EAC declaration the same as an EAC certificate?

No. An EAC Certificate of Conformity is issued by an accredited certification body after the required evaluation. An EAC Declaration of Conformity is adopted and registered by the applicant, who is responsible for its supporting evidence under the applicable rules. The applicable regulation and scheme determine which form is required or permitted.

Can a foreign manufacturer act as the applicant?

No. A manufacturer without an eligible EAEU-registered legal entity or individual entrepreneur cannot act as applicant directly under the stated EAEU framework. The applicant generally must be an EAEU-registered legal entity or individual entrepreneur, and the eligible role depends on the selected scheme. The applicant may be the manufacturer’s authorised representative, seller, importer, or another permitted party when the rules allow it.

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

It can. TR CU 020/2011 addresses electromagnetic compatibility, while TR CU 004/2011 addresses the safety of low-voltage equipment. Equipment in these voltage ranges should be checked against the scope and exclusions of TR CU 004/2011 as well as TR CU 020/2011. The document form may differ under each regulation.

Where can a manufacturer verify an EAC document?

The manufacturer should check the relevant unified EAEU register and its national parts, including the Russian electronic service administered through the accreditation system. The record should identify the correct applicant, manufacturer, product, models, and status. A scanned document or commercial database should not be the only verification source.

Free applicability check

Before testing or preparing an EAC document, confirm the product category, intended use, technical characteristics, HS or TN VED code, market form, and applicable EAEU regulations. The review should establish whether TR CU 020/2011 applies, whether an exclusion is available, whether Annex 3 requires certification, and which applicant and scheme are permitted.

Reestr Garant provides a free applicability check of the product, HS or TN VED code, and applicable regulations for manufacturers entering Russia and the EAEU. Request a free applicability check before commissioning EMC testing or preparing the conformity document.

Related requirements and services

• Compliance for electrical and electronic products
• EAEU compliance for household appliances
• TR CU 004/2011 on low-voltage equipment