TR EAEU 037/2016 restricts the use of specified hazardous substances in covered electrical and electronic products placed on the EAEU market. Check whether the finished model belongs to a listed product category and whether an exclusion applies. For a covered product, assess the relevant materials and confirm that the evidence describes the production configuration you intend to supply.
Check whether the finished product is in scope
Start with the intended function, catalogue model and supplied configuration. Annex 1 lists the product categories. Check that list together with the scope and exclusions in the body of the regulation. Where an order contains several models, assess each model against the list. A combined product description can hide differences in what is supplied or how the equipment is intended to be used.
Record which equipment and accessories are in the shipment. If a power supply or another item is packaged with the main product, identify it by model and confirm how its scope and evidence should be handled. A component report may be useful, but it will only describe the materials and version that it actually covers.
Build evidence around the bill of materials
Use the bill of materials to trace relevant components and materials to suppliers, part numbers and revisions. Document which assemblies use them. For example, a cable contains several materials, and a declaration for its conductor does not establish the composition of its outer insulation. Look for gaps where the documentation covers only part of the supplied item.
- Collect the model list, intended use, assembly drawings and the current bill of materials.
- Request relevant material statements and test reports with enough detail to identify their scope and the supplier part numbers.
- Compare the evidence with the actual board, cable, housing and finishes used in production where relevant.
- Record any evidence gaps and agree with the assessor or laboratory which samples and materials need further checks.
Confirm how conformity will be demonstrated
The regulation provides for declaration of conformity. It also allows certification instead of declaration at the applicant's choice under the applicable provisions. Confirm which scheme fits the product and supply arrangement. The scheme affects which evidence can be used, how testing is handled and what the applicant must retain.
Where tests are needed, give the laboratory a model and material inventory so the report can be matched to the product file. Evidence prepared for another market, including an EU RoHS report, can help identify what has already been assessed. Check its product scope, materials, substances and methods against the EAEU route before relying on it.
Review low-voltage safety and EMC separately
The hazardous-substances regulation deals with composition. Low-voltage safety and electromagnetic compatibility address other aspects of electrical products and require separate scope checks. A piece of equipment can be subject to several regulations, and the evidence for each one answers a different question. Keep a record of which requirements were reviewed and which documents support them.
Before release, compare the assessed model, manufacturer and production configuration across the conformity documents, label and shipment paperwork. Apply the EAC mark only once the applicable conformity requirements have been met.
Recheck the file when suppliers or parts change
Set up a way for production and purchasing to flag revisions that affect the materials covered by the file. A new board supplier or a substitute for a plastic housing can introduce different material evidence even where the equipment's name and function stay the same. Record the change and confirm whether the existing assessment covers it before using the revised configuration for supply.
Frequently asked questions
Does every electrical product fall under TR EAEU 037/2016?
Check the actual product against the categories listed in Annex 1 and the scope exclusions. Electrical function alone does not settle applicability.
Can an EU RoHS report support an EAEU file?
It can be useful evidence when the tested model and materials match the product being assessed. Review the scope and confirm its acceptability under the applicable EAEU procedure.
Can several models use the same material evidence?
Map the common and different parts for each model. The evidence may be relevant to shared materials where the identifiers and revisions match, subject to the scope and scheme.
Does a hazardous-substances declaration cover electrical safety?
The declaration for TR EAEU 037/2016 covers restricted substances under that regulation. Review electrical safety and EMC under their applicable rules.
Compare the certificate and declaration routes and check what evidence applies to your product.