On March 1, 2020 the Technical Regulation TR EAEU 037/2016 “On Limitation of Use of Hazardous Substances in Electrical and Radio-Electronic Products” (hereafter — the Regulation) entered into full force in the EAEU. From this day on it is not allowed to import and sell most electronic goods without documents proving conformity to requirements of the Regulation.
The Regulation is similar to the European Union Directive 2011/65/EU (also known as RoHS — Restriction of Hazardous Substances Directive), and specifies the requirements on the use of the following six hazardous materials in equipment:
|Hazardous substance||Maximum permitted concentration, % NMT|
|4. Hexavalent chromium||0.1|
|5. Polybrominated biphenyls||0.1|
|6. Polybrominated diphenyl ethers||0.1|
What products are subject to TR EAEU 037/2016?
The new Regulation covers domestic equipment (e.g. washing machines, refrigerators, telephones), personal computers (PC) and PC peripherals (scanners, printers), light sources (light bulbs, light fixtures), cables and many more.
The full list of products is provided in Annex N 1 to the Regulation.
This Regulation does not apply to medical devices, toys, high-voltage equipment and other goods, as there are other dedicated technical regulations adopted or prepared for such products, which also limit the levels of the hazardous substances.
The list of goods in TR EAEU 037/2016 regulation is not identical to the list of the European RoHS Directive.
IFCG experts will identify your goods and tell, whether this regulation applies to them — contact us!
What document should be obtained?
Manufacturers and importers of products should apply for a Declaration of Conformity. Optionally, applicants may obtain a Certificate of Conformity instead of the Declaration of Conformity.
Only a person or legal entity registered within the EAEU may apply for an EAC document (Declaration or Certificate).
If you do not have a representative in the EAEU, we may issue a document on your behalf. Your partners and dealers will be able to use the obtained document without any limitations.
As a general rule, the document is issued after tests of the goods. The regulation stipulates the possibility to pass tests:
- in accredited EAEU laboratories;
- in manufacturer’s laboratories or other test laboratories and centers, including foreign ones.
Yet, there are not many EAEU accredited laboratories for the moment — only four. Because of heavy workload, it may take up to 2 months to obtain a test report from them.
How are product tests conducted?
Test methods are governed by the EAEU standards (GOSTs), their list is provided in the Decision of the EEC Board N108 dd. 29.08.2017. These standards essentially agree (are harmonized) with international IEC 62321 series of standards.
All test methods stipulate partial or complete dismantling of test samples into homogeneous components. Each such component is tested separately for the level of hazardous substances with the appropriate methods (e.g., mass spectrometry or X-ray spectrometry).
We are ready to provide full assistance at all stages of obtaining EAC documents proving conformity to the TR EAEU 037/2016:
- we will choose the most relevant laboratory for your product;
- we will help you to go through formalities and import samples for tests;
- we will arrange and control the testing process;
- we will register the declaration (or obtain the certificate).
Contact us today.
Use of RoHS reports
If your product has EU declaration of conformity to the RoHS directive, it has passed tests already, and it is highly likely that the test results may be accepted as conforming to TR EAEU 037/2016.
Test reports received from foreign laboratories may be used only after a preliminary analysis of such reports by a competent person and only accompanied with a translation into Russian.
We will advise you on when such test reports from foreign laboratories may be used, and what information they should contain.
If you already have foreign reports and certificates, we will review them, create a technical record based on them and register the declaration of conformity. If your documents do not fully comply with requirements of the EAEU, we will provide you with advice on corrections and amendments, or assist in testing your product in a Russian laboratory.
We are ready to assist you in obtaining a conformity document to the TR EAEU 037/2016 under any circumstances and at any step:
Tell us the name of your product, its characteristics, HS codeWe will analyze the information and figure out:
— whether your product is subject to the TR EAEU 037/2016 or other technical regulations (TR CU 004/2011, TR CU 020/2011 and others),
— whether technical documents and reports from foreign laboratories, if any, can be used,
— what other permits will be needed for import and sale of goods.
We will help you to import samples of goods for testsWe will obtain all required documents and permits to import samples and will perform customs clearance.
We will find the most suitable laboratories and arrange the testsOur experts consider not only laboratory equipment, technical infrastructure and accreditation, but also their ability to perform tests for all technical regulations at a single location and using the minimum number of samples, which will allow to save your money and time.
We will obtain the final document (declaration or certificate) and deliver it to you