EAC declaration of conformity for Russia and the EAEU

For Russian declarations, registration is handled through the relevant Federal Accreditation Service information system. The applicable registration route and official register must be checked for the document type and jurisdiction.

An EAC Declaration of Conformity is an official mandatory conformity assessment document that the applicant adopts and registers under its own sole legal responsibility. It is used only when the applicable EAEU technical regulation and product list prescribe or permit declaration. A product that requires certification cannot use a declaration instead.

The first decision is therefore product classification, not form completion. Reestr Garant reviews the product, its intended use and technical documentation before identifying whether the route is an EAC declaration, an EAC Certificate of Conformity, state registration or another procedure.

Who this service is for

This service is intended for foreign manufacturers and exporters preparing to place regulated products on the market in Russia or another EAEU member state. It also supports an importer, seller or authorised representative when the applicable rules allow that party to act as the applicant for a particular product or batch.

Does every product entering Russia need an EAC document? No. Mandatory conformity assessment applies when the relevant EAEU technical regulation and official product list cover the product. Products outside the applicable mandatory scope do not acquire an EAC requirement merely because a competitor uses one or because a distributor requests a familiar document.

The form of assessment is prescribed by the applicable rules. An applicant cannot select a declaration for convenience, and a voluntary certificate or manufacturer quality passport cannot replace a mandatory EAC Declaration of Conformity. A refusal or non-applicability letter does not itself replace a declaration where one is required.

Reestr Garant can help determine the regulatory route, organize the evidence review and coordinate registration support. The applicant adopts the declaration. An accredited certification body issues an EAC Certificate of Conformity when certification is the required route.

What is checked before work starts

Before any assessment route is chosen, the product must be matched to its technical regulation and official product scope. The review considers the product’s function, construction, materials, operating conditions, hazards and intended users. Its commercial name alone is not enough to establish the legal category.

• What the product is and what it does.
• Whether it is finished equipment, a component, material, personal protective equipment or another regulated product.
• Whether it is intended for consumers, professional users or industrial use.
• Whether it uses electricity, pressure, machinery, hazardous substances or another regulated characteristic.
• Whether it is supplied as a complete product, component or spare part.
• Whether the supply concerns serial production, a batch or consignment, or a single item.
• Where and under what conditions the product will be used.

The official directory of active EAEU technical regulations and the relevant product lists provide the starting point for this classification. A product may fall under more than one regulation. The applicable registration rules and product scope determine whether a consolidated declaration is possible.

Protective footwear illustrates why intended use matters. Footwear falls within personal protective equipment when it is declared to protect the user from harmful or dangerous factors. In that case, TR CU 019/2011, “On the safety of personal protective equipment,” is relevant. The required assessment form depends on the product’s purpose and the applicable requirements.

GOST standards may support testing or demonstrate compliance when they appear in an applicable official list or have another legal basis for use. A technically suitable GOST reference is not automatically mandatory. The assessment must identify the legal basis for using the standard and confirm that the evidence covers the actual product.

Commercial descriptions such as “industrial footwear,” “smart device,” “machine” or “medical accessory” do not decide the route. The technical regulation, official product scope and intended use determine whether the product needs an EAC declaration of conformity, an EAC certificate or another form of conformity assessment.

Documents to prepare

The evidence file depends on the product, applicable technical regulation and declaration scheme. The manufacturer should normally prepare a clear product description, model information and manufacturing details before the review begins. No single document set applies to every EAEU declaration of conformity.

A test report supports conformity assessment; it is not an EAC Declaration of Conformity. The same distinction applies to a technical passport, risk assessment, safety justification and operating manual. These materials may form part of the evidence file where the regulation or scheme requires them, but none is a universal substitute for the registered declaration.

When a scheme requires testing in an accredited testing laboratory, a report from a non-accredited or voluntary laboratory cannot replace that required evidence. Existing reports are reviewed for product identity, test methods, scope and acceptance under the applicable rules before they are relied upon.

CE documentation may help explain the product’s design and previous testing, but it does not automatically satisfy EAEU requirements. The technical file must be mapped to the applicable EAEU regulation, and missing tests, translations, product identification or applicant documents must be addressed before registration.

Step-by-step process

This workflow summarizes the practical work. It does not replace the legal conditions established by the applicable technical regulation, product list and assessment scheme.

1. Submit the product profile

The manufacturer provides the product description, model range, intended use, technical characteristics, manufacturing location and planned supply format. Product literature and photographs can assist the review, but they do not replace technical documentation.

2. Confirm the regulatory scope

Reestr Garant identifies the applicable EAEU technical regulation or regulations and checks the relevant official product scope. The review determines whether mandatory assessment applies and whether the required form is declaration, certification, state registration or another procedure.

3. Select the declaration scheme

Declaration schemes are selected only after classification. EEC Council Decision No. 44 of 18 April 2018 establishes six standard declaration schemes: 1d, 2d, 3d, 4d, 5d and 6d. It does not establish a declaration scheme 7d.

• Scheme 1d applies to serially produced goods and uses the applicant’s own evidence, including manufacturer production control and sample testing in an in-house or selected laboratory.
• Scheme 2d applies to a batch or consignment and uses the applicant’s own evidence and sample testing without mandatory factory production control.
• Scheme 3d applies to serial production and requires sample testing in an accredited testing laboratory together with manufacturer production control.
• Scheme 4d applies to a specific batch or consignment and requires sample testing in an accredited testing laboratory.
• Scheme 5d applies to serially produced equipment where finished-product testing cannot take place before installation, or to complex machinery, and requires formal type examination.
• Scheme 6d applies to serial production and requires sample testing in an accredited testing laboratory, a certified quality management system and continuing QMS surveillance.

Individual technical regulations may prescribe only part of this set. The applicable regulation determines the available route, so a customer cannot request a preferred scheme before the product is classified.

4. Confirm the applicant

The parties identify the legal entity or individual entrepreneur registered in an EAEU member state that can act as the applicant. A manufacturer that is not registered as an eligible EAEU legal entity or individual entrepreneur cannot itself apply under the relevant schemes. The applicant’s authority must correspond to the product, supply format and applicable scheme.

5. Review the evidence

The specialist checks the technical documentation, operating manuals, product descriptions, supply documents and test reports. The review also confirms whether the evidence identifies the same models and manufacturing sites that will appear in the registered EAC declaration.

6. Complete testing or other assessment

Testing and production controls follow the selected scheme. Where accredited laboratory testing is mandatory, the applicant must use evidence that meets that condition. Where certification applies instead, the accredited certification body performs the required assessment and makes the certification decision.

7. Sign and register the declaration

In Russia, the applicant signs the electronic filing with an enhanced qualified electronic signature under the applicable registration rules; other member states have their own procedures. A consultant or testing coordinator cannot adopt the declaration on the applicant’s behalf as the legal decision-maker.

In Russia, registration follows the applicable Russian procedure; for other EAEU states, check the relevant national registration rules and register. The relevant record should be checked by registration number, active status, product models, applicant, manufacturer and applicable technical regulations.

8. Mark and maintain the product

The EAC mark may be affixed only after all required conformity assessment procedures under all applicable EAEU technical regulations have been completed and registered. Decision No. 711 prescribes the Eurasian Conformity mark, and its size must allow legibility and may not be less than 5 mm. Product, package and accompanying-document marking applies where required and technically possible.

Applicant and authorised representative in the EAEU

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

A foreign manufacturer can use an authorised representative of the manufacturer established in the EAEU under a formal contract covering product compliance and safety liability. For serial production declaration schemes, only the manufacturer or its EAEU authorised representative may act as the applicant. For batch schemes, an EAEU-registered importer or seller may also qualify where the applicable rules allow it.

The manufacturer remains responsible for providing accurate product and production information. The applicant adopts the declaration, keeps the supporting evidence and carries responsibility within the applicable legal framework. A service provider may prepare documents, coordinate laboratory work and support electronic registration, but it does not become the applicant merely by providing those services.

Certification centers and consulting agencies do not issue declarations. They can provide preparatory and testing coordination services. The applicant’s adoption of the declaration remains a separate legal action, and a certificate cannot be created by completing an EAC declaration form.

Timing and price drivers

There is no universal turnaround time for an EAC declaration. The timeframe is assessed after classification because it depends on the laboratory testing program, the readiness of the technical documentation, the applicant arrangement and the selected scheme. A product cannot receive a reliable schedule before those conditions are reviewed.

The applicable regulation and scheme set the term of the declaration. For a batch or single item, the applicable regulation determines the relevant condition.

The cost depends on the actual evidence and assessment route, including:

• product complexity and the number of models;
• the number of applicable technical regulations;
• whether declaration or certification is required;
• the selected scheme and whether it uses the applicant’s own evidence or an accredited laboratory;
• the availability and acceptability of existing test reports;
• sample testing and sample logistics;
• technical documentation review and preparation;
• technical translation and language adaptation;
• production control, type examination or QMS activities where the scheme requires them;
• the need for an EAEU authorised representative;
• the number of products, batches or manufacturing sites.

Reestr Garant provides an estimate only after reviewing the product profile and evidence file. No fixed price or processing promise can be stated before the applicable product scope and scheme are known.

Common mistakes

Do not request an EAC declaration before confirming that declaration is the legally applicable form. A product may require an EAC Certificate of Conformity, another conformity procedure or no mandatory document under the regulation being considered. Starting with a template can produce the wrong scheme, incomplete evidence, an incorrect applicant or a record that does not cover the supplied product.

A common error is treating a CE marking as an EAC approval. CE marking belongs to the European Union framework. An EU declaration, CE certificate where used in a particular sector, or EU test report may provide technical background, but it does not replace the EAEU assessment required for Russia or another EAEU market.

Another error is using a non-accredited report where the selected scheme requires an accredited testing laboratory. The laboratory status and report scope must be checked before the report is placed in the evidence file.

Manufacturers also need to review changes after registration. EEC Council Decision No. 44 treats declarations and certificates differently after registration, and a declaration does not follow the same formal design-change notification procedure as a certificate. A change to the product, manufacturing process or supporting information should therefore be assessed against the applicable regulation, scheme and registration rules before continued supply.

Submitting inaccurate data or ungrounded evidence in a registered declaration can create administrative liability under Article 14.44 of the Russian Code of Administrative Offences. Articles 14.43 and 14.45 contain separate sanctions for specified technical-regulation and sales violations, while Article 14.46 addresses affixing the EAC mark without confirmed conformity and valid registration.

FAQ

What is an EAC declaration of conformity?

An EAC Declaration of Conformity is an official mandatory conformity assessment document adopted and registered by the applicant under its own legal responsibility. It confirms conformity with the applicable EAEU technical regulation only where that regulation provides declaration as the required or permitted form. It is not an EAC Certificate of Conformity.

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

The applicant adopts an EAC Declaration of Conformity and submits it for electronic registration using the required evidence and procedure. An accredited certification body performs the certification assessment and issues an EAC Certificate of Conformity. Both documents have mandatory legal force, and neither is a simplified substitute for the other.

Can a foreign manufacturer register an EAC declaration directly?

Can a foreign manufacturer register an EAC declaration directly? It depends on the applicant’s EAEU registration and eligibility under the applicable scheme. A foreign manufacturer can use an EAEU authorised representative under a formal contract covering product compliance and safety liability. The applicable scheme determines whether an importer or seller may act for a batch.

What is included in an EAC declaration form?

There is no universal form that determines the route for every product. The registered record identifies the applicant, manufacturer, product, applicable technical regulations and other information required by the registration system. The legal validity comes from the electronic register record, not from an edited template or scanned paper document.

Is CE marking enough to sell a product in Russia or the EAEU?

No. CE marking belongs to the European Union conformity framework. Where EAEU requirements apply, the product must follow the applicable EAEU technical regulation and use the required EAC conformity assessment route. CE documents may support a technical review, but they do not replace EAC registration.

Where can an EAC declaration be checked?

Check the relevant national or EAEU register; FSIS Rosaccreditation provides access to Russian records. The appropriate register depends on the document type and regulatory field. Check the registration number, active status, models, applicant, manufacturer and applicable technical regulations rather than relying on an unofficial copy.

What is EAC in railway products?

EAC is the Eurasian Conformity marking system, not a separate universal railway approval. A railway product must be classified by its function, product category and intended use under the applicable EAEU rules. The result may be a declaration, certificate or another assessment route determined by those rules.

Free product check

Send the product description, technical documentation and intended supply format for a free product check. Reestr Garant will review the product, its HS/TN VED code and the applicable regulations before discussing the evidence, applicant and assessment route.

If you already have CE documents, test reports or technical manuals, request an evidence review. Those materials may support an EAEU assessment, but they must first be checked for scope, product identity, laboratory status and compliance with the applicable scheme.

Send product details through the form below for a free product check before choosing an EAC declaration form and to determine whether the product requires an EAC Declaration of Conformity, an EAC Certificate of Conformity or another EAEU conformity route.

See our starting price examples for specific procedures or request a quote for your products.