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EAC mark: conformity for the Eurasian Economic Union

The EAC mark (Eurasian Conformity, Евразийское соответствие) is the single mark of circulation of products on the market of the Eurasian Economic Union. For an electronic product it usually rests on three texts: TR CU 004/2011 (low-voltage safety), TR CU 020/2011 (EMC) and TR EAEU 037/2016 (hazardous substances). This page reads those texts as they stand after the 2022 amendments: which products each one covers, when a certificate is mandatory and when a declaration is enough, who may apply, what the mark and the documentation must look like, and where radio and encryption sit outside the EAC regime.

The Treaty on the Eurasian Economic Union was signed on 29 May 2014 and entered into force on 1 January 2015. Belarus, Kazakhstan and Russia are the founding members. The accession agreement of Armenia was signed in Minsk on 10 October 2014, and that of Kyrgyzstan in Moscow on 23 December 2014. The Union lists Uzbekistan and Cuba as observer states.

Technical regulations are now adopted by the Council of the Eurasian Economic Commission (EEC), hence "TR EAEU". The older ones were adopted by the Customs Union Commission, which preceded it, hence "TR CU". The 2022 amendments replaced the references to the "Customs Union" in TR CU 004/2011 and TR CU 020/2011 by references to the Union, but the regulations kept their TR CU numbers.

Certification bodies and test laboratories must be accredited and entered in the unified register of conformity assessment bodies of the Union (the wording introduced by the 2022 amendments). Certificates and registered declarations go into the unified register of issued certificates and registered declarations, which each member state feeds through its national part. The registers are searchable from the EAEU portal.

The three regulations an electronic product usually meets

Section titled “The three regulations an electronic product usually meets”
RegulationAdopted byIn forceLatest amendment of the textForm of assessment
TR CU 004/2011, safety of low-voltage equipmentCustoms Union Commission Decision No. 768 of 16 August 201115 February 2013EEC Council Decision No. 90 of 10 June 2022Certificate for listed products, declaration otherwise
TR CU 020/2011, EMC of technical meansCustoms Union Commission Decision No. 879 of 9 December 201115 February 2013EEC Council Decision No. 91 of 10 June 2022, in force 11 December 2022Certificate for listed products, declaration otherwise
TR EAEU 037/2016, restriction of hazardous substancesEEC Council Decision No. 113 of 18 October 20161 March 2018(none listed by the EEC)Declaration, certification optional

Both 2022 decisions take effect 180 calendar days after official publication; the EEC page for TR CU 020/2011 gives 11 December 2022 as the date its amendments took effect. A product covered by several regulations must meet all of them, and the EAC mark may only be applied once every applicable regulation has been satisfied (TR CU 004/2011, Article 8(5)).

TR CU 004/2011: a voltage window, not "all electrical equipment"

Section titled “TR CU 004/2011: a voltage window, not "all electrical equipment"”

Article 1(1) applies the regulation to electrical equipment designed for a rated voltage from 50 to 1000 V AC or from 75 to 1500 V DC (inclusive). Below those values the equipment is outside its scope. A mains power supply or charger sits inside it; a device that is itself supplied at a few volts DC by that charger does not. Decision No. 90 added to Article 2 a definition of low-voltage equipment by its upper limits (rated voltage on every input and output not above 1000 V AC and 1500 V DC), but did not change the 50 V and 75 V lower bounds of Article 1(1).

Decision No. 90 rewrote the exclusions in Article 1(2). The regulation does not apply to, among others: equipment specially designed for use on air, water, land and underground transport; used (second-hand) equipment; equipment within the scope of TR CU 010/2011 (machinery), TR CU 011/2011 (lifts) or TR CU 012/2011 (explosive atmospheres), except cables, wires and cords; medical devices; defence products; and components whose safety can only be assessed once built into other equipment (connectors, printed circuit boards, relays, integrated circuits, capacitors, resistors and similar).

TR CU 020/2011: EMC, but explicitly not the radio spectrum

Section titled “TR CU 020/2011: EMC, but explicitly not the radio spectrum”

The regulation covers technical means that can generate electromagnetic disturbance or whose operation depends on external disturbance. As amended in 2022, it does not apply to components used by manufacturers of other equipment and not intended for independent use by an end user, to equipment passive in EMC terms (Annex 1 lists examples: cables, resistive heaters without thermostat, unamplified headphones and loudspeakers, incandescent lamps, passive broadcast antennas), to used equipment, to medical devices or to defence products.

Article 1(4) states that the regulation does not govern relations connected with use of the radio frequency spectrum, which are governed by the communications legislation of the member states. That is the textual basis for the rule that an EAC mark is not a radio approval.

TR EAEU 037/2016: a positive list and six substances

Section titled “TR EAEU 037/2016: a positive list and six substances”

TR EAEU 037/2016 applies only to the products in its Annex 1, a closed list. It includes household appliances, power supplies and chargers, computers and their peripherals (servers, laptops, tablets, keyboards and mice, removable storage, monitors, printers, scanners, speakers and headphones, projectors, biometric readers, webcams, modems, UPS), telecommunication terminals (fixed and mobile telephones, portable radio stations, RFID tags), office equipment, power tools, lighting, electronic musical instruments, vending and gaming machines, cash registers and ATMs, cables up to 500 V (except fibre-optic), circuit breakers and residual current devices, and fire and security detectors.

Article 3 excludes, among others: equipment above 1000 V AC or 1500 V DC unless Annex 1 provides otherwise, electric toys, photovoltaic panels, equipment intended solely for transport, batteries and accumulators (including those placed on the market inside a product), used products, measuring instruments and medical devices.

Substance (Annex 2)Maximum in homogeneous material, by weight
Lead0.1 %
Mercury0.1 %
Cadmium0.01 %
Hexavalent chromium0.1 %
Polybrominated biphenyls (PBB)0.1 %
Polybrominated diphenyl ethers (PBDE)0.1 %

The EU RoHS list has ten entries since Delegated Directive (EU) 2015/863 added four plasticisers (DEHP, BBP, DBP, DIBP). The EAEU list has six: those four are not in Annex 2. Annex 3 holds the exemptions, mostly mercury limits per lamp type.

The regulation entered into force on 1 March 2018, but EEC Board Decision No. 24 of 28 February 2017 allowed products to be manufactured and placed on the market without assessment against it until 1 March 2020.

Certificate or declaration: the lists decide

Section titled “Certificate or declaration: the lists decide”

TR CU 004/2011 and TR CU 020/2011 work the same way (Article 7 of each). Products in the regulation annex must be certified. Products outside the annex are declared, and the applicant may choose certification instead. Certification is also required when the applicant does not apply the standards of the voluntary list (Article 6(1)), or when no such standards exist.

Product family (abridged)TR CU 004/2011 annex (certificate)TR CU 020/2011 annex 3 (certificate)
Household appliances (kitchen, laundry, cleaning, climate, personal care, audio and video, receivers)ListedListed
Power supplies, chargers, voltage stabilisers (household)ListedListed
Automatic controllers for household equipment, remote controls and control panels, controllersAdded by the 2022 amendmentNot listed
Personal computers, including system units; cash registersListed (wording of the 2022 amendment)Listed (wording of the 2022 amendment)
Household and office equipment connected to a PC: scanners, printers and copiers (including multifunction devices), monitors, UPS, active speakers, multimedia projectorsListed (wording of the 2022 amendment)Listed (active speakers only when mains-powered)
Power tools (hand-held and portable electric machines)Removed by the 2022 amendment, which replaced the item by electric heating toolsListed
Electronic musical instrumentsListedListed
Cables, wires and cordsListedOutside scope (EMC-passive, Annex 1)
Circuit breakers and residual current devicesListed, with fuses, switchgear, switches, contactors and starters added in 2022Listed when electronically controlled

The annex wording is the reference: always read the consolidated list against the product and its customs code (the EEC publishes a list of products with their customs codes for each regulation).

The scheme labels are Cyrillic in the texts: "с" for certification, "д" for declaration. They are transliterated here as s and d.

SchemeFormForEvidenceWho may apply
1sCertificateSerial productionType testing by an accredited laboratory, analysis of the production, surveillance by the certification bodyManufacturer or its authorised person
3sCertificateBatchSample testingImporter, or manufacturer (authorised person)
4sCertificateSingle itemTesting of the itemImporter, or manufacturer (authorised person)
1dDeclarationSerial productionOwn evidence: testing and production control by the manufacturerManufacturer or its authorised person
2dDeclarationBatch or single itemOwn evidence: testingManufacturer (authorised person) or importer
3dDeclarationSerial productionTesting in an accredited laboratory, production controlManufacturer or its authorised person
4dDeclarationBatch or single itemTesting in an accredited laboratoryManufacturer (authorised person) or importer
6dDeclarationSerial productionAccredited testing plus certified quality management systemManufacturer or its authorised person

Validity: under TR CU 004/2011 and TR CU 020/2011, a certificate or declaration for serial production is valid for at most 5 years; for a batch or a single item no period is set. A declaration takes effect on the day it is registered.

TR EAEU 037/2016 (section VII) uses declaration: schemes 1d, 3d, 6d for serial products, 2d and 4d for batches. For 1d and 2d, testing may be done in the applicant's own laboratory, an accredited laboratory or another laboratory, at the applicant's choice. The applicant may replace the declaration by certification under schemes 1s, 2s, 6s (serial) or 3s (batch).

EEC Board Decision No. 41 of 20 March 2018 (in force 1 July 2018) sets the procedure. The declaration, drawn up on the single form of Board Decision No. 293 of 25 December 2012, is filed with a body authorised by the member state, which may be an accredited certification body whose scope covers the product. Filing may be electronic, signed with an electronic signature. The body registers the declaration by assigning a number, or refuses with reasons, within 5 working days. The declaration is then entered in the national part of the unified register.

Applicant, importer and document retention

Section titled “Applicant, importer and document retention”

The regulations do not use the phrase "local representative". They define the authorised person (уполномоченное изготовителем лицо): a legal entity or individual registered in a member state, appointed by the manufacturer under a contract to act on its behalf in conformity assessment and placing on the market, and to bear responsibility for non-conformity. The importer is a legal entity or individual entrepreneur registered in a member state that has concluded a foreign trade contract with a foreign manufacturer or seller, places the product on the market and is responsible for its conformity.

In practice, a manufacturer established outside the Union certifies or declares serial production through an authorised person, while an importer can only apply for a batch or a single item (schemes 3s, 4s, 2d, 4d).

The document set (technical documentation, test reports, certificate or declaration) must be kept in the territory of the Union: by the manufacturer or authorised person for at least 10 years after production of the equipment stops, and by the importer or authorised person for at least 10 years after the last item of a batch is sold.

As with harmonised standards in the EU, the EEC publishes for each regulation a list of standards whose voluntary application ensures compliance, and a list of test method standards. Most entries are interstate GOST adoptions of IEC and CISPR standards.

RegulationStandards list in forceEntries relevant to IT, AV and radio equipment
TR CU 004/2011EEC Board Decision No. 55 of 11 May 2023GOST IEC 62368-1-2014 (IEC 62368-1), and still GOST IEC 60950-1-2014 and GOST IEC 60065-2013
TR CU 020/2011EEC Board Decision No. 77 of 29 June 2021, amended by Decision No. 79 of 9 July 2024GOST CISPR 32-2015 (CISPR 32), GOST CISPR 24-2013, GOST CISPR 35-2019 (CISPR 35) applicable from 1 January 2025, GOST EN 301 489-1 for radio equipment EMC

Two consequences for a test plan. First, the lists cite dated GOST editions, not the latest IEC or CISPR edition, so a report to the current IEC edition has to be mapped to the GOST edition listed. Second, the TR CU 004/2011 list still carried the GOST adoptions of IEC 60950-1 and IEC 60065 in 2023, although IEC withdrew both in 2024: check the current list rather than assuming the EAEU follows the IEC withdrawal.

Language. Since the 2022 amendments, Article 5(5) of TR CU 004/2011 and TR CU 020/2011 requires operating documents in Russian and, where the law of the member state where the product is sold requires it, in that state language. Trade marks, proper names, place names and other names and details may be given in other languages; units may use their international symbols. For household equipment the information listed in Article 5(4) must be on paper (electronic copies may be added); for non-household equipment, documents may be supplied in electronic form only. If the information fits, it may be put on the equipment or its packaging instead of a separate document.

Product marking. The name or designation of the equipment, its safety-related parameters, the manufacturer name or trade mark and the country of manufacture go on the equipment; manufacturer and designation also go on the packaging. Marking must be legible and placed where it can be inspected without dismantling with tools.

The EAC mark. Decision No. 711 sets the graphic rules:

RuleWhat the text says
ShapeThree stylised letters E, A, C drawn with right angles, of equal height and width, forming the proportions of a square, on a light or a contrasting background
SizeSet by the manufacturer; base size at least 5 mm; elements must stay distinguishable to the naked eye
ColourSingle colour, contrasting with the surface
DurabilityAny method giving a clear image for the whole service life
WhereOn each unit of product, on the packaging or in the accompanying documents, as each technical regulation specifies

TR CU 004/2011 and TR CU 020/2011 (Article 8) require the mark on each unit and in the operating documents. It may go only on the packaging and in the documents when it cannot be applied to the equipment itself.

Radio and encryption: outside EAC, partly at Union level

Section titled “Radio and encryption: outside EAC, partly at Union level”

An EAC mark covers safety, EMC and substances. Two other layers matter for a BLE, Wi-Fi, LTE or LoRa product.

Spectrum use is national (TR CU 020/2011, Article 1(4)). In Russia the federal supervisory authority for communications is Roskomnadzor. National rules on frequency use and on communication equipment apply in addition to EAC and are not set by the EAEU technical regulations.

Import of radio-electronic devices is a Union-level non-tariff measure: Annex 15 to EEC Board Decision No. 30 of 21 April 2015 covers radio-electronic means and high-frequency devices in section 2.16 of the single list, including those built into other goods. Release for domestic consumption requires a licence or evidence that the device is in the single register of radio-electronic means and high-frequency devices, unless the device is in the exemption list of Annex 2 to that regulation.

Encryption is governed by Annex 9 to the same Decision, for goods in section 2.19 of the single list. Import is allowed on the basis of a licence, a permit (conclusion), or a notification entered in the single register of notifications. The text sets the procedure:

Point of Annex 9Rule
Who filesThe manufacturer or a person authorised by it, once, on the basis of evidence produced by the manufacturer
Who registersThe "agreeing body", the national security authority of a member state (in Russia, the FSB)
LanguageRussian; technology, protocol and algorithm names may be in Latin script
Third-country manufacturerThe notification must be legalised
DeadlineRegistration or refusal, plus entry in the single register, within 10 working days of filing
PublicationThe single register of notifications is published on the Union website

Where a radio device contains encryption, the radio import documents must be accompanied by the encryption permit or the notification details (Annex 15, points 10 and 12).

DateEvent
15 July 2011Customs Union Commission Decision No. 711 defines the EAC mark
15 February 2013TR CU 004/2011 and TR CU 020/2011 enter into force
29 May 2014Treaty on the Eurasian Economic Union signed
1 January 2015Treaty enters into force
21 April 2015EEC Board Decision No. 30 on non-tariff measures (encryption, radio-electronic means)
1 March 2018TR EAEU 037/2016 enters into force
1 July 2018Decision No. 41 on registration of declarations takes effect
1 March 2020End of the TR EAEU 037/2016 transition (Decision No. 24)
10 June 2022EEC Council Decisions No. 90 and No. 91 amend TR CU 004/2011 and TR CU 020/2011
11 December 2022Amendments to TR CU 020/2011 take effect (EEC page)
11 May 2023New standards lists for TR CU 004/2011 (Decision No. 55)
1 January 2025GOST CISPR 35-2019 applicable under TR CU 020/2011 (Decision No. 79)
Common claim (some made by earlier versions of this page)What the texts say
TR EAEU 037/2016 covers "electronic equipment in general"It covers only the closed list of Annex 1, and Article 3 excludes batteries, toys, measuring instruments, medical devices and others
EAEU RoHS mirrors EU RoHSAnnex 2 lists six substances; the four plasticisers (DEHP, BBP, DBP, DIBP) added to EU RoHS by Directive (EU) 2015/863 are absent
TR CU 004/2011 covers every electrical productArticle 1(1) limits it to 50 to 1000 V AC and 75 to 1500 V DC rated equipment
The certificate is reserved for "higher-risk" or "complex industrial" equipmentCertification is required for the products in each regulation annex, which are mostly household and IT products: appliances, chargers, PCs, printers, monitors
Declaration testing must always be done in an accredited laboratorySchemes 1d and 2d rest on evidence produced by the applicant; under TR EAEU 037/2016 those tests may be done in a laboratory of the applicant
The foreign manufacturer must use a "Eurasian representative" for everythingThe texts define the authorised person (needed for serial production) and the importer (who can apply for batches and single items)
Encryption notification is a Russian FSB procedureIt is a Union procedure (Annex 9 to Decision No. 30); the FSB is the Russian registering body, and registered notifications go into a single Union register
The mark has a "minimum contrast" and size "depending on product surface"Decision No. 711 sets a base size of at least 5 mm, a single colour contrasting with the surface, and leaves the actual size to the manufacturer
The EAEU follows the IEC withdrawal of IEC 60950-1The 2023 standards list for TR CU 004/2011 still includes GOST IEC 60950-1-2014 next to GOST IEC 62368-1-2014
An English-only or French-only manual is acceptable for professional equipmentRussian is required for all operating documents; only the paper requirement is relaxed for non-household equipment
  1. Map the product to each regulation: check the voltage window of TR CU 004/2011, the exclusions of TR CU 020/2011 and the Annex 1 list of TR EAEU 037/2016. Do it separately for the device and for its external power supply.
  2. Read the annexes to see whether certification is mandatory, and pick a scheme (serial production or batch).
  3. Appoint the applicant: an authorised person registered in a member state, under contract, for serial production; or an importer for a batch.
  4. Choose the standards from the current EEC lists (GOST editions), and have the tests done where the scheme requires an accredited laboratory entered in the unified register.
  5. Compile the document set, keep it in the Union territory for 10 years, and prepare Russian-language documentation and marking.
  6. Obtain the certificate from an accredited certification body, or register the declaration (5 working days under Decision No. 41).
  7. Apply the EAC mark (base size at least 5 mm, single colour) on each unit and in the documents.
  8. For radio and encryption, check the single register of radio-electronic means, prepare the encryption notification (legalised for a manufacturer outside the Union) and the national spectrum and communication rules of the target state.
  9. Maintain: renew within 5 years for serial production, track amendments to the standards lists and the regulations.

Sources & references

  1. EEC, technical regulations in force (list), Eurasian Economic Commission eec.eaeunion.org/comission/department/deptexreg/tr/TRVsily.php
  2. TR CU 004/2011 on safety of low-voltage equipment (text, adoption and amendment decisions), Eurasian Economic Commission eec.eaeunion.org/comission/department/deptexreg/tr/Down_Volt.php
  3. TR CU 020/2011 on electromagnetic compatibility of technical means (text, amendments, standards lists), Eurasian Economic Commission eec.eaeunion.org/comission/department/deptexreg/tr/EMS.php
  4. TR EAEU 037/2016 on restriction of hazardous substances in electrical and electronic products, Eurasian Economic Commission eec.eaeunion.org/comission/department/deptexreg/tr/TR_EEU_037.php
  5. EEC Council Decision No. 90 of 10 June 2022 amending TR CU 004/2011, Eurasian Economic Union legal portal docs.eaeunion.org/docs/ru-ru/01433953/err_14062022_90
  6. EEC Council Decision No. 91 of 10 June 2022 amending TR CU 020/2011, Eurasian Economic Union legal portal docs.eaeunion.org/docs/ru-ru/01433956/err_14062022_91
  7. EEC Board Decision No. 24 of 28 February 2017, transitional provisions of TR EAEU 037/2016, Eurasian Economic Union legal portal docs.eaeunion.org/docs/ru-ru/01413155/clcd_02032017_24
  8. EEC Board Decision No. 55 of 11 May 2023, standards lists for TR CU 004/2011, Eurasian Economic Union legal portal docs.eaeunion.org/docs/ru-ru/01439659/err_12052023_55
  9. EEC Board Decision No. 79 of 9 July 2024, amending the TR CU 020/2011 standards lists (GOST CISPR 35-2019), Eurasian Economic Union legal portal docs.eaeunion.org/docs/ru-ru/01445244/err_12072024_79
  10. Customs Union Commission Decision No. 711 of 15 July 2011 on the single mark of circulation (EAC), Eurasian Economic Union legal portal docs.eaeunion.org/documents/193/854/
  11. EEC Board Decision No. 41 of 20 March 2018 on registration of declarations of conformity, Eurasian Economic Union legal portal docs.eaeunion.org/documents/253/3550/
  12. EEC Board Decision No. 30 of 21 April 2015 on non-tariff measures (Annex 9 encryption, Annex 15 radio-electronic means), Eurasian Economic Commission eec.eaeunion.org/comission/department/catr/nontariff/30.php
  13. Annex 9 to EEC Board Decision No. 30, regulation on import and export of encryption (cryptographic) means (FSB licensing centre copy), FSB of Russia, Centre for licensing, certification and protection of state secrets clsz.fsb.ru/files/download/reshenie_N_30_prilogenie_N_9.pdf
  14. EAEU unified portal (registers of certificates, declarations and conformity assessment bodies), Eurasian Economic Union portal.eaeunion.org/
  15. Eurasian Economic Union, history and member states, Eurasian Economic Union eaeunion.org/?lang=en
  16. EEC, Eurasian Economic Commission (English), Eurasian Economic Commission eec.eaeunion.org/en/
  17. Roskomnadzor, Federal Service for Supervision of Communications (Russia, English), Roskomnadzor rkn.gov.ru/eng/
  18. Commission Delegated Directive (EU) 2015/863 amending Annex II to Directive 2011/65/EU (RoHS), EUR-Lex eur-lex.europa.eu/eli/dir_del/2015/863/oj

Frequently asked questions

What is the EAC mark and which states does it cover?
EAC stands for Eurasian Conformity (Евразийское соответствие). It is the single mark of circulation of products on the market of the Eurasian Economic Union, defined by Customs Union Commission Decision No. 711 of 15 July 2011. It shows that the product has passed every conformity assessment procedure set by the technical regulations that apply to it. The Union has five member states: Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan. The mark may be applied when the assessment was carried out in any member state.
Does the EAC mark cover radio products?
It covers their electrical safety (TR CU 004/2011, for equipment within its voltage window), their EMC (TR CU 020/2011) and their hazardous substances (TR EAEU 037/2016). It does not cover use of the radio spectrum: Article 1(4) of TR CU 020/2011 says spectrum use is governed by the communications legislation of the member states. Import of radio-electronic devices and of goods with encryption functions is controlled separately under EEC Board Decision No. 30 of 21 April 2015 (Annexes 15 and 9).
What is the difference between TR CU and TR EAEU?
TR CU are technical regulations adopted by the Customs Union Commission from 2011, before the Eurasian Economic Union existed (for example TR CU 004/2011 and TR CU 020/2011, both in force since 15 February 2013). TR EAEU are adopted by the Council of the Eurasian Economic Commission under the 2014 Treaty (for example TR EAEU 037/2016 on hazardous substances, in force since 1 March 2018). Both remain in force side by side, and a product must meet every one that covers it.
Certificate or declaration, who decides?
The technical regulation decides. TR CU 004/2011 and TR CU 020/2011 each have an annex listing products that need a certificate (schemes 1s, 3s or 4s): household appliances, household power supplies and chargers, personal computers, printers, monitors, scanners and other listed families. Everything else in scope is declared (schemes 1d, 2d, 3d, 4d or 6d), and the applicant may opt for certification instead. TR EAEU 037/2016 uses declaration, with certification as an option chosen by the applicant.
Who can be the applicant?
For serial production, the manufacturer or its authorised person, which the regulations define as a legal entity or individual registered in a member state and appointed by contract with the manufacturer to act on its behalf and to bear responsibility for non-conformity. For a batch or single item, the importer (a resident of a member state) may also apply. The document set must be kept in the territory of the Union for at least 10 years after production stops, or after the last item of a batch is sold.
Which language is required for documentation and the label?
Russian, plus the state language of the member state where the product is sold when that state requires it (Article 5(5) of TR CU 004/2011 and TR CU 020/2011 as amended in 2022). Trade marks, proper names and units may appear in other languages. For household equipment the required information must be on paper; documentation for non-household equipment may be supplied in electronic form only.
How long is an EAC certificate or declaration valid?
Under TR CU 004/2011 and TR CU 020/2011, at most 5 years for serially produced equipment; no validity period is set for a batch or a single item. A declaration takes effect on the day it is registered. Under Decision No. 41 of 20 March 2018, the registering body has 5 working days to register it or refuse registration.
Does an EAC certificate settle export or sanctions questions?
No. EAC conformity is a product requirement under the Union technical regulations. Export controls and sanctions that bind the manufacturer are separate legal regimes, outside the scope of the EAEU texts cited on this page, and need their own legal analysis before any certification work.