EAC mark: conformity for the Eurasian Economic Union
Guide · EAC / EAEU
The EAC mark (Eurasian Conformity, Евразийское соответствие) is the unified conformity mark of the Eurasian Economic Union. For its five member states (Russia, Belarus, Kazakhstan, Armenia, Kyrgyzstan), it covers electrical safety, electromagnetic compatibility and restriction of hazardous substances, but it does not extend to the radio regime, which remains governed by each member state, notably by Roskomnadzor in Russia. This page describes the institutional setup of the EAEU, the articulation between TR CU and TR EAEU, the two certification routes (certificate and declaration), the requirements for a local representative and Russian-language documentation, and the most frequent pitfalls for a European manufacturer.
Institutional setup of the EAEU
Section titled “Institutional setup of the EAEU”The Eurasian Economic Union (EAEU, UEEA in French) is a regional economic union formally established by the Treaty on the Eurasian Economic Union signed on 29 May 2014 in Astana and in force since 1 January 2015. It continues and institutionalises the Customs Union built from 2010. Five states are members at the time of writing:
- Russian Federation (founding member),
- Republic of Belarus (founding member),
- Republic of Kazakhstan (founding member),
- Republic of Armenia (joined in 2015),
- Kyrgyz Republic (joined in 2015).
The supranational body of the Union is the Eurasian Economic Commission (EEC), based in Moscow. The EEC adopts technical regulations, maintains the unified register of certificates and declarations, and coordinates mutual recognition of certification bodies accredited by the national authorities. The register is searchable on the unified portal at portal.eaeunion.org.
At national level, accreditation of certification bodies and testing laboratories falls under each member state's authority (Rosakkreditatsiya in Russia, BelAk in Belarus, equivalent authorities in Kazakhstan, Armenia and Kyrgyzstan). A body accredited in one member state is, in principle, recognised in the others: an EAC certificate issued in Belarus is valid in Russia, and vice versa.
TR CU, TR EAEU: the regulatory stack
Section titled “TR CU, TR EAEU: the regulatory stack”The EAC mark is not a single regulation. It attests a product's conformity to one or several technical regulations adopted by the EEC. Two generations coexist.
TR CU, first generation
Section titled “TR CU, first generation”TR CU (Technical Regulations of the Customs Union) were adopted from 2010 to 2011 under the Customs Union that preceded the EAEU. They remain in force as long as a more recent TR EAEU has not superseded them.
| Regulation | Subject | EU functional equivalent |
|---|---|---|
| TR CU 004/2011 | Safety of low-voltage equipment | Low Voltage Directive (LVD) |
| TR CU 020/2011 | Electromagnetic compatibility | EMC Directive (EMCD) |
| TR CU 037/2016 | Restriction of hazardous substances | RoHS Directive |
TR EAEU, current generation
Section titled “TR EAEU, current generation”TR EAEU (Technical Regulations of the EAEU) form the post-2015 generation. They may carry over, complete or replace a TR CU. For information and telecommunication equipment, the structuring regulation is TR EAEU 037/2018, on the safety of information equipment, aligned with the international standard IEC 62368-1 (which superseded IEC 60950-1 and IEC 60065 in the audio-video and IT domain).
| Regulation | Subject | Reference IEC standard |
|---|---|---|
| TR EAEU 037/2018 | Safety of information equipment | IEC 62368-1 |
| TR CU 020/2011 (still in force) | EMC | CISPR 32, CISPR 35, IEC 61000 series |
| TR CU 004/2011 | Low-voltage safety | IEC 60335 series, IEC 61010 series |
| TR CU 037/2016 | Hazardous substances | EN 50581 / IEC 63000 (RoHS logic) |
TR mapping to IEC standards
Section titled “TR mapping to IEC standards”EAEU TRs rest mainly on international IEC standards, adopted under GOST IEC references (Russian national transposition of the IEC standard). In practice, a test report run against an IEC standard can serve as a basis for the EAC dossier, but the tests must be conducted or repeated by a laboratory accredited in a member state, and the report must be presented in the format expected by the Eurasian certification body.
| Product family | Applicable TR | Harmonised standard |
|---|---|---|
| IT and multimedia equipment | TR EAEU 037/2018 + TR CU 020/2011 | IEC 62368-1, CISPR 32 |
| Household appliances | TR CU 004/2011 + TR CU 020/2011 | IEC 60335 series, CISPR 14 series |
| Industrial low-voltage equipment | TR CU 004/2011 + TR CU 020/2011 | IEC 61010 series, IEC 61000 series |
| Electronic equipment in general | TR CU 037/2016 | GOST IEC 63000 (RoHS) |
| Radio equipment (non-radio conformity layer) | Applicable TR CU and TR EAEU | Corresponding standards |
For the radio layer proper (transmitter approval, frequency plans, power limits, cryptographic notification), see the dedicated section below.
Certification routes: certificate or declaration
Section titled “Certification routes: certificate or declaration”The EAC regime distinguishes two main routes. The choice is not at the manufacturer's discretion: it is set by the applicable TR, which specifies, for each product family, the required procedure.
Certificate of conformity
Section titled “Certificate of conformity”The certificate of conformity is the route reserved for higher-risk categories. It is issued by a certification body accredited in a member state, on the basis of:
- a documentary review of the product technical file,
- testing run by an accredited laboratory,
- for some categories, an on-site production audit,
- for serial certificates, a periodic surveillance programme.
The certificate carries a number issued by the body and is recorded in the EEC unified register. Its typical validity is multi-year, subject to maintained delivery conditions (product configuration, production site, surveillance programme).
Declaration of conformity
Section titled “Declaration of conformity”The declaration of conformity is drawn up by the manufacturer or its Eurasian representative, on the basis of testing in an accredited laboratory. It is recorded in the EEC unified register after a completeness check by an accredited body. It applies to lower-risk categories designated by the applicable TR. Responsibility for conformity rests on the declarant.
| Criterion | Certificate of conformity | Declaration of conformity |
|---|---|---|
| Decision actor | Accredited certification body | Manufacturer or Eurasian representative |
| External review | Full dossier review, testing, possible audit | Completeness check, laboratory testing |
| Target categories | Higher risk (set by the TR) | Lower risk (set by the TR) |
| Surveillance | Periodic programme for serial certificates | Under declarant's responsibility |
| Number | Body number recorded in the register | Declaration registration number |
Both instruments converge in the unified register kept by the EEC, publicly searchable. Verification of a certificate or declaration number is a routine control at customs clearance and during market surveillance.
The radio perimeter: Roskomnadzor and FSB in Russia
Section titled “The radio perimeter: Roskomnadzor and FSB in Russia”This is the most structural mistake in the Eurasian dossier: assuming that the EAC mark covers radio approval. It does not.
What EAC does cover on the radio side
Section titled “What EAC does cover on the radio side”Through TR CU 020/2011 and the TR on the safety of information equipment, EAC covers, for a radio product:
- EMC (conducted and radiated emissions, immunity),
- electrical safety of the complete product (power supply, ergonomics, safety marking),
- restriction of hazardous substances (RoHS-equivalent).
What it does not cover
Section titled “What it does not cover”EAC does not cover:
- radio approval as such (frequency plans, radiated power limits in a band, emission type),
- authorisations of use of frequency bands,
- cryptographic functions embedded in the product.
In Russia, those layers fall under distinct authorities:
| Authority | Scope |
|---|---|
| Roskomnadzor (Federal Service for Supervision of Communications) | Notification and approval of radio equipment, frequency plans, conditions of use |
| FSB (Federal Security Service) | Cryptographic notification for products embedding encryption functions, including commercial ones (Wi-Fi, Bluetooth, VPN) |
For Belarus, Kazakhstan, Armenia and Kyrgyzstan, equivalent authorities cover the same layers, with their own procedures. The EAC mark is necessary but not sufficient for placing a radio product on the market in those states.
| Layer | EAC (TR CU / TR EAEU) | Roskomnadzor and FSB (Russia) |
|---|---|---|
| Electrical safety | Covered | Not covered |
| EMC (emissions, immunity) | Covered | Not covered |
| Hazardous substances (RoHS) | Covered | Not covered |
| Radio approval (band, power) | Not covered | Covered (Roskomnadzor) |
| Cryptographic notification | Not covered | Covered (FSB) |
The practical consequence: a transmitter product (BLE, Wi-Fi, LTE, LoRa, etc.) destined for the Russian market requires, in addition to the EAC mark, a Roskomnadzor notification for the radio layer and, when encryption functions are present, an FSB notification. Project planning must run those layers in parallel rather than sequentially.
Eurasian local representative
Section titled “Eurasian local representative”The applicant for a certificate or declaration of conformity must be a legal entity resident in an EAEU member state. A European, American or Asian manufacturer cannot file directly.
The Eurasian representative (often called "applicant" in English) may be:
- a subsidiary of the manufacturer incorporated in a member state,
- an importer or official distributor resident in a member state,
- a specialised certification provider, contracted for the role.
The representative carries several obligations:
- retention of the technical file for the duration prescribed by the applicable TR,
- reception and handling of requests from the certification body and surveillance authorities,
- declaration of material product changes that could invalidate the certification,
- coordination in case of incident, recall or market-surveillance request.
The appointment is contracted in writing, generally annexed to the certification dossier. The choice of representative is not neutral: its financial robustness, responsiveness and familiarity with the regime drive the procedure timeline and the maintenance of the certificate over the product life cycle.
Russian-language documentation and labelling
Section titled “Russian-language documentation and labelling”Russian is the working language of the EAEU and the mandatory language for official documentation.
Regulatory text
Section titled “Regulatory text”- Certificate or declaration: written in Russian, signed and recorded in the EEC register in Russian.
- User manual: present in Russian for consumer-facing products; bilingual presentation with the national language of a member state (Belarusian, Kazakh, Armenian, Kyrgyz) may be required depending on the target market.
- Commercial label: mandatory information (product designation, manufacturer, importer, storage and use conditions) in Russian.
- Safety marking: pictograms and safety wording in Russian.
EAC mark on the product
Section titled “EAC mark on the product”The EAC logotype is normalised (fixed proportions, minimum contrast, minimum size depending on product surface). It must be permanently affixed, visible without disassembly and readable without magnification under normal use. For products too small to carry the full mark, a waiver allows part of the marking to be moved to the packaging and documentation, provided the EAC logo appears on at least one of the physical supports.
Documentation in English or French only is a frequent ground for rejection during market surveillance of consumer-facing products.
GOST-R, GOST-B and the EAC mark
Section titled “GOST-R, GOST-B and the EAC mark”For products covered by a TR CU or TR EAEU, the EAC mark replaced the legacy mandatory national marks GOST-R (Russia) and GOST-B (Belarus).
| Mark | Current status |
|---|---|
| EAC | Mandatory unified mark for products covered by a TR CU or TR EAEU |
| GOST-R | Historical Russian mark, still used on a voluntary basis for categories not covered by a TR or as a complementary quality mark |
| GOST-B | Belarusian equivalent, analogous status to GOST-R |
GOST-R does not open the Eurasian single market: it covers Russia only and carries no regulatory weight for products subject to a TR. Its presence on a product does not exempt from the EAC mark when the latter is required.
EAC, CE and FCC: comparison
Section titled “EAC, CE and FCC: comparison”For a product team familiar with the European and US marks, EAC sits as follows.
| Criterion | CE (EU) | FCC (US) | EAC (EAEU) |
|---|---|---|---|
| Market covered | 27 EU member states + EEA | United States | 5 EAEU member states |
| Logic of placing on the market | Conformity to directives (LVD, EMCD, RED, etc.) | Conformity to Part 15 (radio), sectoral regulations | Conformity to TR CU and TR EAEU |
| Radio mark included | Yes (via RED) | Yes (FCC ID, Part 15) | No (Roskomnadzor in Russia, equivalents elsewhere) |
| Main route | Self-declaration or Notified Body depending on the directive | DoC or Certification (TCB) depending on class | Certificate or declaration depending on the TR |
| Mandatory local representative | EU authorised representative for non-EU manufacturer | FCC agent for non-US grant holder | Eurasian-resident applicant |
| Language of label and manual | Language of the member state of placing on the market | English | Russian, bilingual with national language as required |
| Public register | Notified Bodies, Eudamed (by sector) | FCC ID public in the FCC register | EEC unified register, portal.eaeunion.org |
| Restriction of hazardous substances | RoHS, separate directive | No direct federal equivalent | TR CU 037/2016, integrated into the EAC regime |
See CE, FCC and RED for the European and US regimes in detail, and CE vs FCC, EMC scope for the direct comparison between the two main Western regimes.
Step-by-step procedure
Section titled “Step-by-step procedure”Without committing to a precise schedule, the typical sequence for a first EAC certification is as follows.
- Identify the applicable TRs for the product (TR CU 004/2011, TR CU 020/2011, TR CU 037/2016, TR EAEU 037/2018, possible sectoral TRs) and the required route (certificate or declaration).
- Identify the distinct radio perimeter: Roskomnadzor (Russia) and equivalent authorities in the other member states, FSB for cryptographic functions in Russia. These layers run in parallel to EAC, not included within it.
- Appoint a resident applicant in an EAEU member state, by written contract. Without that applicant, no filing is possible.
- Select an accredited certification body in a member state, taking into account the primary target market and the sanctions context applicable to the manufacturer.
- Run the tests in an accredited laboratory, against the GOST IEC standards adopted by the TRs (safety, EMC, hazardous substances).
- Compile the technical dossier: schematics, bills of materials, antenna plan where applicable, test reports, user manual translated into Russian.
- File the certificate request or the declaration through the Eurasian applicant, record the number in the EEC unified register.
- Run in parallel the Roskomnadzor notification for the radio layer and, where applicable, the FSB notification for cryptographic functions (distinct cycle, distinct authorities).
- Affix the EAC mark on the product and packaging, finalise the Russian-language label and manual.
- Maintain: change management, surveillance programme for serial certificates, monitor the register.
Sanctions context since 2022
Section titled “Sanctions context since 2022”From 2022 onwards, several Western certification bodies and a number of laboratories accredited in Russia suspended their services for the Russian market. The legal framework of EAC remained in place: TR CU and TR EAEU are in force, the EEC continues to operate, the unified register remains accessible, and free circulation between the five member states is preserved.
The practical channel changed. Issuance of EAC certificates for products entering Russia now flows mostly through Belarusian, Kazakh or regional certification bodies. The choice of body and Eurasian applicant has become both a regulatory and a legal decision.
Compliance with the sanctions regimes applicable to the manufacturer (EU sanctions, OFAC, national regimes of exporting countries) falls under the manufacturer's legal counsel. That analysis is prior to any certification step: a product that a European manufacturer is not authorised to export to Russia under sanctions does not become exportable because it carries an EAC certificate. This page covers the technical framework of EAC; the sanctions analysis is a separate question that requires specific legal counsel.
Common pitfalls
Section titled “Common pitfalls”| Pitfall | Consequence |
|---|---|
| Assuming the EAC mark covers radio | Transmitter blocked at import for lack of Roskomnadzor notification |
| Omitting FSB cryptographic notification for a Wi-Fi or Bluetooth product | Blocking at Russian customs, commercial withdrawal |
| Applying TR CU 020/2011 when a more recent TR EAEU applies | Dossier rejected, rework of the technical file |
| Documentation and label in English only | Rejection during market surveillance of consumer products |
| Appointing the Eurasian applicant late in the project | Filing blocked, industrialisation delayed |
| Conflating voluntary GOST-R with the mandatory EAC mark | Product non-compliant with the TRs despite a GOST-R logo |
| Ignoring the sanctions context before launching the procedure | Legal risk on the manufacturer, independent of the technical dossier |
| Selecting the certification body on price alone | Weak certificate maintenance, surveillance lost |
Further reading
Section titled “Further reading”- CE marking: European reference regime
- FCC: US regime, another major gateway
- RED: EU radio layer, functional equivalent of Roskomnadzor for the EU
- Certification timeline: cross-cutting orders of magnitude
- Parallel EU and US certification: test-campaign pooling logic
- Glossary: definitions of EEC, TR CU, TR EAEU, GOST-R, Roskomnadzor, FSB
See also
Section titled “See also”- Switzerland: product certification and the EU-CH MRA
- India: BIS (CRS), TEC (MTCTE) and WPC (ETA) certifications
- GCC: Kuwait, Bahrain, Qatar, Oman and the G-Mark (GSO)
- TDRA (UAE) and SDPPI (Indonesia): radio approval
Sources & references
- EEC, Eurasian Economic Commission (English) , Eurasian Economic Commission eec.eaeunion.org/en/
- Technical regulations of the EAEU, Eurasian Economic Commission , Eurasian Economic Commission www.eurasiancommission.org/en/act/texnreg/deptexreg/
- EAEU unified portal (register of certificates and declarations) , Eurasian Economic Union portal.eaeunion.org/
- Roskomnadzor, Federal Service for Supervision of Communications (Russia, English) , Roskomnadzor rkn.gov.ru/eng/
- Treaty on the Eurasian Economic Union (signed 2014, in force 2015) , Eurasian Economic Union docs.eaeunion.org/docs/en-us/0003610/itia_05062014