Electrical Product Compliance in
Eurasian Economic Union
(EAEU)
Presented by Livia Kecerova
Regulatory Specialist
Compliance & Risks
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Contents
I. Overview of the Eurasian Economic Union (EAEU) and the Union’s Product Safety Compliance
i. Eurasian Economic Union (EAEU) – Situation Past and Present
ii. EAEU’s regulatory regime and requirements for electrical products
• Hierarchy of normative documents
o The Treaty, International Agreements, Orders and Decisions of the Union’s bodies, Technical
Regulations and other Acts and Rules
• Compliance of electrical products placed on the market in the Eurasian Economic Union
i. Unified List of products for which the mandatory requirements are Established within the
Customs Union and the List of Products Subject to Mandatory Conformity
ii. Importation of electrical products
iii. Mandatory requirements for safety aspects of electrical products found in applicable Technical
Regulations
II. Three Regulatory areas related to the Electrical Product Compliance across the EAEU
i. Restriction of Hazardous Substances in Electrical and Electronic Equipment
ii. Requirements for the Energy Efficiency of Energy-consuming Devices
iii. Waste electrical and electronic equipment Management
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s Product
Safety Compliance
Eurasian Economic Union (EAEU) – Situation Past and Present
Historical facts
• In 1995, Belarus, Kazakhstan and the Russian Federation signed the ‘Troika’ Agreement on the Customs
Union
• The Eurasian Economic Community known as the ‘EurAsEC’ was established in 2000 originally
comprising of Belarus, Kazakhstan, Kyrgyzstan, the Russian Federation and Tajikistan
• The year was 2007 and Belarus, Kazakhstan and the Russian Federation signed a Treaty on the Single
Customs Territory which essentially formed the Customs Union. The Common Economic Space was
officially launched in 2010 by the three countries.
• The ‘four freedoms’: Free movement of goods, services, capital and labor were implemented in 2012,
same year the Eurasian Economic Commission began to ‘operate’
• May 2014 – Member States of the Customs Union and the Common Economic Space signed the Treaty
on the Eurasian Economic Union concluding the formation process
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s Product
Safety Compliance
Eurasian Economic Union (EAEU) – Situation Past and Present
Present situation
• Year 2015 saw the new stage of the Eurasian integration from the commencement of the Eurasian
Economic Union’s operation through signing the Treaty of Accession of the Republic of Armenia in
January, to the accession of the Kyrgyz Republic in May
• The head of Member States joined in the mutual aspiration and hope that the EAEU will bring a common
good for the member nations, strengthen stability in the Eurasian space and encourage further movement
and trade within the Eurasian region
• Despite number of set-backs (anti-Russian sanctions imposed in the aftermath of Crimea’s annexation)
and doubts as to the Union’s preparedness, Tajikistan and Uzbekistan expressed their interests
• Discussions proposing establishing trade and economic relations, partnership and cooperation also
started with likes of Vietnam, China, potentially Turkey, Iran, India, Mongolia and Azerbaijan
• Today, the Union consists of Armenia, Belarus, Kazakhstan, Kyrgyz Republic and Russia
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s
Product Safety Compliance The EAEU’s regulatory regime and requirements for electrical products
Hierarchy of the Union’s Laws
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The Treaty of the Eurasian
Economic Union
International Treaties within the
Union
Decisions and Orders of the Supreme Eurasian Economic Council
International Agreements of the Union with a Third
Party
Decisions of the Eurasian Economic Commission
Acts, Lists, Rules and Technical Regulations
approved by the Decisions and
OrdersDecisions of the Intergovernmental
Council
I. Overview of the Eurasian Economic Union (EAEU) and the Union’s
Product Safety Compliance The EAEU’s regulatory regime and requirements for electrical products
Compliance of electrical products placed on the market in the Eurasian Economic Union
i. Unified List of products for which the mandatory requirements are established within the Customs
Union and the List of products subject to Mandatory Conformity Assessment
• Two Unified Lists were approved through the enactment of Decision No. 526 of 2011 as amended;
and Decision No. 620 of 2011 respectively.
• Accordingly, the mandatory requirements within the Customs Union were issued for 66 product
types, not limited to:
o Machinery and Low voltage equipment
o High voltage equipment
o Telecommunication equipment
o Elevators
for which there are mandatory requirements in existence.
• Furthermore, Decision No. 620 of 2011 stipulates that electrical equipment is subject to Mandatory
Conformity Verification. Thankfully, it also provides respective standards compliance to which shall
be tested.
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s
Product Safety Compliance The EAEU’s regulatory regime and requirements for electrical products
Compliance of electrical products placed on the market in the Eurasian Economic Union
ii. Importation of electrical products
What needs to be submitted to the
Customs authorities for imported electrical
products during Customs clearance?
Decision governing the Importation of electrical products into the EAEU
Commission Decision No. 294 of 25 December 2012 on Importation into
the Customs Union Territory products for
which Mandatory Requirements are
established within the Custom Union
Documents proving the compliance of such
products (goods) with mandatory requirements or information about such
documents, including
Conformity assessment (confirmation) document provided under the applicable
Technical Regulations of the Union
Any other documents provided for by the legislation of the Member State in whose
territory the goods/products are placed under the customs procedure
Customs Declaration
Certificate of Conformity or Declaration of Conformity of the Customs Union in an approved
format;
Certificate of Conformity or Declaration of Conformity issued under the legislation of the
Member State in whose territory the goods are placed under the customs procedure
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s Product
Safety Compliance The EAEU’s regulatory regime and requirements for electrical products
Compliance of electrical products placed on the market in the Eurasian Economic Union
iii. Mandatory requirements for safety aspects of electrical products found in applicable Technical
Regulations (TR)
• The safety of any product circulated within the territory of the Eurasian Economic Union is ensured through the
application of TRs
• Generally adopted by the Eurasian Economic Commission
• TRs applicable to electronics cover all aspects of the product’s life cycle from safe and effective design, through
the packaging, labelling, conformity assessment/ certification and testing, to the provision of convenient
disassembly at the end of their life
• EAEU’s TRs are directly applicable in all the Member States whilst ensuring the harmonization of the legislation
and product safety rules across the Union
• In order to meet the requirements of Technical Regulations, the applicable international, regional (interstate) or
national standards may be followed/applied creating the presumption of conformity with TR
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I. Overview of the Eurasian Economic Union (EAEU) and the Union’s
Product Safety Compliance The EAEU’s regulatory regime and requirements for electrical products
Compliance of electrical products placed on the market in the Eurasian Economic Union
iii. Mandatory requirements for safety aspects of electrical products found in applicable Technical
Regulations (TR)
• Current number of effective TRs of the EAEU: 44
• Current number of draft TRs of the EAEU: 11
• Number of Lists of harmonized standards provided as integral part of the TRs: 35
TRs particularly relevant to electrical products:
• TR CU 004/2011 on the safety of low-voltage equipment
• TR CU 010/2011 on the safety of machinery and equipment
• TR CU 020/2011 on the electromagnetic compatibility of technical means
• TR EAEU 037/2016 on the restriction of hazardous substances in electrical and electronic equipment
Other possibly relevant TRs:
• TR CU 005/2011 on the safety of packaging
• TR CU 012/2011 on the safety of equipment intended for work in explosive environments
• TR CU 032/2013 on the safety of equipment operating under excessive pressure
• Draft TR on energy efficiency requirements for energy-consuming devices
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II. Three Regulatory areas related to the Electrical Product Compliance across the
EAEU
i. Restriction of Hazardous Substances in Electrical and Electronic Equipment
Scope of application
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TR EAEU 037/2016 aims to protect the consumer, the environment, and
human life and health and to prevent activities that mislead consumers (end-
users) of electrical and electronic equipment (EEE) regarding the content of
hazardous substances.
It will come into force on 1 March 2018.
EEE means all in-scope electrical and electronic equipment intended to be
placed on the market in the territory of the EAEU (Union)
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II. Three Regulatory areas related to the Electrical Product Compliance across the
EAEU
i. Restriction of Hazardous Substances in Electrical and Electronic Equipment
Requirements 1 – Restrictions & Exemptions
Technical Regulation requires EEE to be designed and manufactured not containing:
a) Hazardous substances as per Annex 2;
b) Homogeneous materials containing hazardous substances in concentrations above the maximum
allowable level as specified in Annex 2 to this Technical Regulation.
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Special restrictions and exemptions from Annex 2
restrictions applicable to specific equipment and their
applications are set in Annex 3.
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II. Three Regulatory areas related to the Electrical Product Compliance across the
EAEU
i. Restriction of Hazardous Substances in Electrical and Electronic Equipment
Requirements 1 – Restrictions & Exemptions
Hazardous substances
Permissible concentration of hazardous
substance by weight in homogeneous
materials (percentile) not exceeding
Cadmium (CAS No: 7440-43-9) 0,01%
Hexavalent chromium (CAS No: 18540-29-9) 0,1%
Lead (CAS No: 7439-92-1) 0,1%
Mercury (CAS No: 7439-97-6) 0,1%
Polybrominated Biphenyl (CAS No: 59536-65-1) 0,1%
Polybrominated Diphenyl Ethers (PBDE) 0,1%
• Majority of special exemptions/restrictions laid down in Annex 3 to the EAEU RoHS are
identical to those appearing in Annex III of the RoHS 2 Directive 2011/65/EU.
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II. Three Regulatory areas related to the Electrical Product Compliance across the EAEU
i. Restriction of Hazardous Substances in Electrical and Electronic Equipment
Similarities with and deviations from the European Union RoHS Recast Directive 2011/65/EU
Notable distinctions exist between the EU RoHS Recast Directive and the EAEU’s RoHS TR
EAEU Technical
Regulation 037/2016 on
RoHS
EU RoHS Recast Directive
2011/65/EU
Products in scope
1. Electrical apparatus and
appliances for household
use
2. Electronic computers and
their peripherals (connected
to them)
3. Telecommunication
(terminal
telecommunication)
equipment
1. Large household appliances
2. Small household appliances
3. IT and telecommunications
equipment
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Products in scope
4. Copiers and other electrical
office equipment
5. Electrical tools (manual and
portable electric machines)
6. Sources of light and lighting
equipment, including
equipment built into furniture
7. Electrical music tools
8. Vending machines and
gaming machines
9. Cash registers, ticket
printers, ID card readers,
information kiosks, ATMs,
card terminals
10. Cables, wires, cords
intended for use at a rated
voltage below 500 V AC/DC,
except for fiber optic cables
11. Automatic switches and
residual current devices;
12. Fire, security and fire-
security alarms/detectors
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic
tools
7. Toys, leisure and sports
equipment
8. Medical devices
9. Monitoring and control
instruments including
industrial monitoring and
control instruments
10. Automatic dispensers
11. Other EEE not covered by
any of the categories above.
EAEU Technical
Regulation 037/2016 on
RoHS
EU RoHS Recast Directive
2011/65/EU
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Products not in scope
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
1. Products designed for use
at nominal voltage
exceeding 1000 V AC or
1500 V DC unless
otherwise provided in
Annex 1;
2. Products designed solely
for use as components of
electrical and electronic
equipment that are not
listed in Annex 1;
3. Electric toys;
4. Photovoltaic panels/ solar
panels used as part of the
electrical and electronic
equipment;
1. Equipment which is
necessary for the
protection of the essential
interests of the security of
Member States, including
arms, munitions and war
material intended for
specifically military
purposes;
2. Equipment designed to be
sent into space;
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Products not in scope
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
5. Products designed to be
used in land-based and
orbiting space objects;
6. Products intended solely for
the use of air, water, ground
and underground transport;
7. Batteries and
accumulators, including
those put into circulation on
the territory of the CU as
part of electrical products;
3. Equipment which is
specifically designed, and is
to be installed, as part of
another type of equipment
that is excluded or does not
fall within the scope of this
Directive, which can fulfil its
function only if it is part of
that equipment, and which
can be replaced only by the
same specifically designed
equipment;
4. Large-scale stationary
industrial tools;
5. Large-scale fixed
installations;
6. Means of transport for
persons or goods, excluding
electric two-wheel vehicles
which are not type-approved;
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Products not in scope
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
5. Used electrical and
electronic equipment;
6. Measuring instruments;
and
7. Medical devices
7. Non-road mobile machinery
made available exclusively
for professional use;
8. Active implantable medical
devices;
9. Photovoltaic panels intended
to be used and installed by
professionals for public,
commercial, industrial and
residential applications;
10.Equipment specifically
designed solely for the
purposes of research and
development only made
available on a business-to-
business basis.
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Substance Restrictions
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
No surprises as far as the restrictions of 6 core substances are
concerned
DEHP, BBP, DBP and DIBP:
Not regulated
- Thus far
DEHP, BBP, DBP and DIBP:
0,1% by weight in
homogeneous materials
- Effective 22 July 2019
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Special Restrictions &
Exemptions
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
Mercury in linear
halophosphate lamps with
tube > 28 mm
- Expires 1 March 2020
Mercury in linear
halophosphate lamps with
tube > 28 mm
- Expired 13 April 2012
Lead in solders used in
powerful loudspeakers
- No expiry date set
Absence of provisions on a
mechanism for renewing or
applying for new
exemptions
Lead alloys as solder for
transducers used in high-
powered loudspeakers
- Expired 24 September 2010
The application requirements
for an exemption and the
criteria to inform the decision
on whether or not to grant it
are clearly set out
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Conformity Assessment
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
Option 1: declaration of
conformity by one of the
following schemes:
Declaration Schemes 1d, 2d,
3d or 4d, 6d
Option 2: certification
according to one of the
following schemes:
1c, 2c, 3c, 6c.
Declaration of Conformity is
subject to REGISTRATION
as prescribed by the
Decision N 76 of the College
of the Eurasian Economic
Commission of April 9, 2013
Testing standards: GOST EN
50581-2016 based on EN
50581-2016; and GOST IEC
62321 parts 1, 2, 3, 4 and 5.
Manufacturers are to draw up
the required technical
documentation and carry out
the internal production control
procedure in line with module
A.
Module A = Internal production
No requirement to register
the Declaration of
conformity
Obligation to keep record of
non-compliant products
Presumption of conformity
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Labelling & Marking
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
• Name and (or) product
designation and type,
make, model (if any)
• Main parameters and
characteristics,
• The name and (or)
trademark of the
manufacturer,
• The name of the State in
which the product is made
On a product or alternatively
on its packaging and in the
EEE’s accompanying
documentation
• Registered trade name or
registered trade mark, and
• The address at which they
can be contacted;
• The address must indicate
a single point at which the
manufacturer can be
contacted
• A type, batch or serial
number or other element
allowing its identification.
Required information must be
shown on a product or on the
packaging or in a document
accompanying the EEE
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Transitional provisions
EAEU Technical Regulation
037/2016 on RoHS
EU RoHS Recast Directive
2011/65/EU
1 March 2020: Compliance
deadline: end of transitional
period for equipment without
conformity assessment
22 July 2021 - Compliance
Deadline: default expiry date
for exemptions for EEE in
categories 8 and 9, except for
industrial monitoring and
control instruments for which
the deadline is 22 July 2024;
where not otherwise specified
22 July 2019: Extension of
scope to other electrical and
electronic equipment not
covered by categories 1-10
+
Compliance deadline: limit on
bis (2-ethylhexyl) phthalate,
butyl benzyl phthalate,
dibutylphthalate and diisobutyl
phthalate in EEE except for
medical devices and
monitoring and control
instruments for which this
deadline is 22 July 2021
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II. Three Regulatory areas related to the Electrical Product Compliance across the EAEU
ii. Requirements for the Energy Efficiency of Energy-consuming Devices
• Draft Technical Regulation on Energy Efficiency of Energy-related products was first issued on 20 June 2016;
revised on 14 March 2017
• Developed taking into account the provisions of the EU Directives and Regulations on a subject
• Will apply to electrical appliances made available in EAEU Member States, which have a significant daily and/
or annual electricity consumption and thus have an impact on energy security, environment and ecology, such
as: Refrigerators, freezers, electric induction motors, televisions, household washing machines, dishwashers,
electric lamps, circulation pumps, fans, vacuum cleaners, air conditioners, computers and computer servers,
etc.
• The label must contain:
o The name and/ or designation of the device in question (type, make, model if available),
o Its main features and energy efficiency characteristics,
o The name and/ or the manufacturer's trade mark and
o The place of manufacture.
The information referred to in the labelling should be applied to the power consuming devices, and specified in
the annexed operational documents.
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II. Three Regulatory areas related to the Electrical Product Compliance across the EAEU
iii. Waste electrical and electronic equipment Management
Case Study: Russian Federation Approach
• To date, no harmonized rules on waste electrical and electronic equipment and by extension, the producer’s
extended responsibility (EPR) has been established within the EAEU
• Member States of the EAEU must apply their national waste provisions when dealing with WEEE & EPR
• In Russia, for instance, there isn’t one single piece of legislation applicable to waste electrical and electronic
equipment exclusively, as is the case in the European Union.
• Recent introduction of the EPR principle into the crucial piece of legislation – the Federal Law on Waste
Production and Consumption (FZ No. 89, 1998) in 2015
• The proper implementation of this important amendment was facilitated by number of measures:
o Government Order 1886-p, 2015 “approving the list of finished goods and packaging subject to
recycling after losing their consumer properties”
o Resolution No. 2491/2015 stipulating mandatory collection targets
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The End
Thank you for your attention.
For more information contact:
Livia Kecerova, Regulatory Specialist
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