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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.

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.

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 (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.

RegulationSubjectEU functional equivalent
TR CU 004/2011Safety of low-voltage equipmentLow Voltage Directive (LVD)
TR CU 020/2011Electromagnetic compatibilityEMC Directive (EMCD)
TR CU 037/2016Restriction of hazardous substancesRoHS Directive

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).

RegulationSubjectReference IEC standard
TR EAEU 037/2018Safety of information equipmentIEC 62368-1
TR CU 020/2011 (still in force)EMCCISPR 32, CISPR 35, IEC 61000 series
TR CU 004/2011Low-voltage safetyIEC 60335 series, IEC 61010 series
TR CU 037/2016Hazardous substancesEN 50581 / IEC 63000 (RoHS logic)

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 familyApplicable TRHarmonised standard
IT and multimedia equipmentTR EAEU 037/2018 + TR CU 020/2011IEC 62368-1, CISPR 32
Household appliancesTR CU 004/2011 + TR CU 020/2011IEC 60335 series, CISPR 14 series
Industrial low-voltage equipmentTR CU 004/2011 + TR CU 020/2011IEC 61010 series, IEC 61000 series
Electronic equipment in generalTR CU 037/2016GOST IEC 63000 (RoHS)
Radio equipment (non-radio conformity layer)Applicable TR CU and TR EAEUCorresponding 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.

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).

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.

CriterionCertificate of conformityDeclaration of conformity
Decision actorAccredited certification bodyManufacturer or Eurasian representative
External reviewFull dossier review, testing, possible auditCompleteness check, laboratory testing
Target categoriesHigher risk (set by the TR)Lower risk (set by the TR)
SurveillancePeriodic programme for serial certificatesUnder declarant's responsibility
NumberBody number recorded in the registerDeclaration 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.

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).

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:

AuthorityScope
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.

LayerEAC (TR CU / TR EAEU)Roskomnadzor and FSB (Russia)
Electrical safetyCoveredNot covered
EMC (emissions, immunity)CoveredNot covered
Hazardous substances (RoHS)CoveredNot covered
Radio approval (band, power)Not coveredCovered (Roskomnadzor)
Cryptographic notificationNot coveredCovered (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.

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.

  • 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.

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.

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).

MarkCurrent status
EACMandatory unified mark for products covered by a TR CU or TR EAEU
GOST-RHistorical Russian mark, still used on a voluntary basis for categories not covered by a TR or as a complementary quality mark
GOST-BBelarusian 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.

For a product team familiar with the European and US marks, EAC sits as follows.

CriterionCE (EU)FCC (US)EAC (EAEU)
Market covered27 EU member states + EEAUnited States5 EAEU member states
Logic of placing on the marketConformity to directives (LVD, EMCD, RED, etc.)Conformity to Part 15 (radio), sectoral regulationsConformity to TR CU and TR EAEU
Radio mark includedYes (via RED)Yes (FCC ID, Part 15)No (Roskomnadzor in Russia, equivalents elsewhere)
Main routeSelf-declaration or Notified Body depending on the directiveDoC or Certification (TCB) depending on classCertificate or declaration depending on the TR
Mandatory local representativeEU authorised representative for non-EU manufacturerFCC agent for non-US grant holderEurasian-resident applicant
Language of label and manualLanguage of the member state of placing on the marketEnglishRussian, bilingual with national language as required
Public registerNotified Bodies, Eudamed (by sector)FCC ID public in the FCC registerEEC unified register, portal.eaeunion.org
Restriction of hazardous substancesRoHS, separate directiveNo direct federal equivalentTR 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.

Without committing to a precise schedule, the typical sequence for a first EAC certification is as follows.

  1. 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).
  2. 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.
  3. Appoint a resident applicant in an EAEU member state, by written contract. Without that applicant, no filing is possible.
  4. Select an accredited certification body in a member state, taking into account the primary target market and the sanctions context applicable to the manufacturer.
  5. Run the tests in an accredited laboratory, against the GOST IEC standards adopted by the TRs (safety, EMC, hazardous substances).
  6. Compile the technical dossier: schematics, bills of materials, antenna plan where applicable, test reports, user manual translated into Russian.
  7. File the certificate request or the declaration through the Eurasian applicant, record the number in the EEC unified register.
  8. Run in parallel the Roskomnadzor notification for the radio layer and, where applicable, the FSB notification for cryptographic functions (distinct cycle, distinct authorities).
  9. Affix the EAC mark on the product and packaging, finalise the Russian-language label and manual.
  10. Maintain: change management, surveillance programme for serial certificates, monitor the register.

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.

PitfallConsequence
Assuming the EAC mark covers radioTransmitter blocked at import for lack of Roskomnadzor notification
Omitting FSB cryptographic notification for a Wi-Fi or Bluetooth productBlocking at Russian customs, commercial withdrawal
Applying TR CU 020/2011 when a more recent TR EAEU appliesDossier rejected, rework of the technical file
Documentation and label in English onlyRejection during market surveillance of consumer products
Appointing the Eurasian applicant late in the projectFiling blocked, industrialisation delayed
Conflating voluntary GOST-R with the mandatory EAC markProduct non-compliant with the TRs despite a GOST-R logo
Ignoring the sanctions context before launching the procedureLegal risk on the manufacturer, independent of the technical dossier
Selecting the certification body on price aloneWeak certificate maintenance, surveillance lost

Sources & references

  1. EEC, Eurasian Economic Commission (English) , Eurasian Economic Commission eec.eaeunion.org/en/
  2. Technical regulations of the EAEU, Eurasian Economic Commission , Eurasian Economic Commission www.eurasiancommission.org/en/act/texnreg/deptexreg/
  3. EAEU unified portal (register of certificates and declarations) , Eurasian Economic Union portal.eaeunion.org/
  4. Roskomnadzor, Federal Service for Supervision of Communications (Russia, English) , Roskomnadzor rkn.gov.ru/eng/
  5. Treaty on the Eurasian Economic Union (signed 2014, in force 2015) , Eurasian Economic Union docs.eaeunion.org/docs/en-us/0003610/itia_05062014