Export To The Russian Market Strategies and suggestions to combat the certificative iter

Increasingly companies are faced with the age-old question of the certification required for export to the Customs Union and neighbouring countries.
In fact, those who intend to export their products to the Eurasian Customs Union must obtain certifications that guarantee the compliance of the products with the applicable standards through specific procedures and tests.
Since 2010 – the year of birth of the Customs Union – Russia, Belarus and Kazakhstan – to which Armenia and Kyrgyzstan were later added (the Customs Union was then renamed the Eurasian Economic Union), have prepared a series of technical regulations that provide for the adoption of a single regulation on the conformity assessment of products. These regulations have been drawn up partly following the EC directives, it is in fact easy to notice similarities between the two systems.
The creation of the Eurasian Customs Union makes it possible to export and market products throughout the Union with a single document of conformity since the new certifications are valid and accepted in all Member States.

Without dwelling on this brief article on the regulatory part – which is a specialist subject dealt with by specialised agencies that are also responsible for guiding and supporting the companies that address them – it is nevertheless worth mentioning some aspects that often create confusion in those who do not master the subject. CERTIFICATION or DECLARATION?
The EAC CERTIFICATE is an attestation of product conformity, issued by a notified certification body located within one of the countries of the customs union, following an inspection visit carried out at the production plant and the performance of tests on product samples at an accredited laboratory of the union, with which the conformity is attested.
The EAC DECLARATION OF CONFORMITY is a self-certification, supported by tests provided by the manufacturer or carried out at an accredited laboratory and its own documentation which will then be registered by a certification body.

The choice between the two documents is generally not the responsibility of the producer or in any case of the applicant for certification, but it is the regulations themselves that determine which procedures must be followed and which documents must be produced. In fact, it is up to the competent certification bodies, on the basis of the directives contained in the relevant TR CU regulation, to identify which of the two forms must be followed.
Once you have passed both documental checks and product tests – you can affix the EAC mark (which is the abbreviation of Eurasian Conformity). The technical regulations mainly used in the plant/mechanical field are the following:
TRCU 004/2011: Safety on low voltage equipment
TRCU010/2011: Safety of Machinery and Equipment
TRCU012/2011: Safety of equipment for potentially explosive
TRCU016/2011: Safety of gas-fuelled machinery
TRCU020/2011: Electromagnetic compatibility of hardware
TRCU032/2013: Safety of pressure equipment
TREAEU037/2016: on the restriction of the use of hazardous substances in electrical and radio products
TREAEU043/2017: On fire safety requirements and extinguishing devices (FSS)

Below is a description of the timing and methods by which it is useful to approach the certification aspects.
Many companies often underestimate the importance of these certifications, postponing their achievement until they are explicitly requested. However, the lack of the necessary certifications can lead to customs detentions and to administrative, civil and in some cases even criminal liability, not only on the local counterpart but also on the foreign manufacturer. Minor violations may cost thousands of euros, goods without a certificate may also be seized or the importer may find it impossible to sell or use them because compliance with current regulations is not ensured.
So what is the right way to handle the certification process?
In order to approach the process in the correct way, it is necessary to have a certification strategy. This strategy can only be decided after having carefully examined the certification requests in the order, the products and the type of company/production. It is essential from this point of view to rely on a serious and competent agency that has the necessary experience to develop the best strategy. Choosing a capable and careful partner makes the process much more streamlined and totally eliminates the problems that are often found downstream of a certification process that is not correctly set up (non-compliant technical passports, customs detentions, incomplete documentation, etc.).
Over the years, now more than 10, GA has had the opportunity to develop a very precise certification process that has proved to be very useful both in the bidding and processing phases. The use of this working methodology has meant that no managed practice has ever been contested or rejected by the certification bodies in charge, to the benefit of its customers who have seen all the problems related to the export and installation of their products considerably streamlined. The results of this method of work are demonstrated by the fact that in all these years a practice managed by GA has never been rejected or rejected.

The procedure consists of the following steps:
-Preliminary assessment of documents and customs code applied to the product
-Regulatory analysis
-Definition, in agreement with the client, of the certification strategy
-Identification of the documentation necessary to obtain the certificate
-Support in drawing up the documents required by the technical regulations
-Organisation of the inspection visit – where applicable
-Refinement of documentation

Once the processing and collection of the GA documents has been completed, it is responsible for forwarding the documentation, already verified and checked, to the CERTIFICATION BODY – accredited body in the country of destination of the products – which issues the certificate or registers the declaration. After checking the documentation, the Certification Body, in agreement with GA and the customer, establishes the date of the inspection visit to the manufacturing company, if scheduled. At the end of the inspection and testing, after uploading all the necessary documents on the state site, the Certification Body may issue the certificate or record the statement.
The certification process itself does not take long: we are talking about 45 days at the most. What makes the whole process complicated and cumbersome is the retrieval of the correct information and the required documents.
Often the products, and consequently also the accompanying documentation, undergo changes during the construction phase with respect to the initial technical specifications, in these cases the times often almost double.
A separate analysis, with regard to timing, should instead be made for plants where – to certify the whole assembly
– it is necessary to first have the correct documents from the respective suppliers. Never as in this case is it fundamental that the customer follows the indications of the reference agency to obtain certification within the contractual deadlines and not incur in delays and the charging of penalties.
The certification obtained is entered in the Single Register of certificates and declarations of conformity available on these sites:
GA offers the highest level of support thanks to a team that includes, among others, 8 Russian-speaking technicians, specialized in the applicable regulations for exports to various geographical areas: Russia and the Eurasian Union (TR CU), Algeria (ARH), India (CCoE/PESO), China, Canada (CRN/CSA), Uzbekistan, Azerbaijan and Australia.
EAC: Euroasiatic Conformity
TR CU: Technical regulation of Custom Union (Technical
Regulation of Customs Union)
LoE: Exemption letter
JoS: Safety justification (safety argument)
PT: Technical passport
PAC: Pattern Approval Certificate (metrological certificate)
IVC/LCC/POVERKA: Initial vertification certificate/legal calibration certificate (calibration of the measuring instrument obtained by the accredited laboratory)
VCB: Vendor Certification body
CCoE: certificate of conformity for products intended to be used in potentially explosive areas (Indian market)
ARH: Algerian hydrocarbons regulations
CRN: Canadian Registration Number system (the Canadian method of reviewing and registering the design of pressure vessels, piping systems and the fittings)
CSA approval: certificate of conformity for electrical products intended for use in potentially explosive areas
(US and CANADA market)

Please contact Viviana Liparulo, for any further information: