EAC Declaration of Conformity Registration FAQs.
What packages of documents will be attached to the registration office of the Russian FSA Certification and Accreditation Service when registering an EAC Declaration of Conformity?
When issuing the EAC Declaration of Conformity (EAC DOC), all fields containing information on the registration** are filled in, and the applicant's registration information, a copy of the DUL (Authorized Person Contract) or VFII (Foreign Manufacturer Function), test reports, and other documents confirming that the product meets the relevant CU TR (EAEU) requirements are uploaded to the section of the registry.
What is the difference between EAC Declaration of Conformity and EAC Certification?
In the form of a confirmation of conformity. Legally, the legal status of these two forms is the same. The practical difference is that EAC certification is carried out by a third party (certification body) who is independent of the applicant and impartial, whereas in the case of the EAC Declaration of Conformity, all the registration procedures and all the responsibilities are borne by the applicant himself. There is also a difference in terms of penalties - for unreliable EAC declarations of conformity: the penalty is from 100,000 rubles per unit, while in terms of EAC certification the penalties are more stringent: from 400,000 rubles per certificate.
What are the benefits of the Customs Union EAC certification for manufactured goods?
There are no other benefits. Mandatory EAC certification is a prerequisite for the circulation, importation and sale of products related to goods subject to mandatory requirements of laws and regulations.
How much time and money does the product EAC certification process cost?
The Customs Union EAC certification consists of several simple stages: 1. Consideration of applications and documents, preparation of certification procedures; 2. Selection and identification of products and standard samples; 3. Analyze the production status (if it is a mass production product certification); 4. Conduct tests; 5. Analyze all obtained results, including test reports; 6. Make a decision and issue an EAC Certificate of Conformity (if the result is positive) or make a decision to refuse to issue a certificate. Therefore, the conditions and cost of the service are determined by the actual cost of these procedures and depend on the location where they are performed and the complexity of the inspection. Therefore, it is not possible to have a fixed certification fee (if all the procedures are actually performed).
What is Inspection Control?
Batch EAC certificate is"Disposable"EAC Certificate. They are based on the detection of a specific batch of product and are applicable to that batch of product. ButWhen EAC certification is applied to mass-produced products, only one periodic verification (audit test) is required once a yearto confirm that an unlimited number of EAC-certified products are still qualified and safe after certification assessment. Surveillance verification is carried out in the form of inspection control (on-site audit).。It is the same as EAC certification, except that it is not achieved through the issuance of EAC certificatesRather, this is achieved by extending and confirming the validity of previously issued EAC certificates.
How do I check if my product has an EAC Certificate of Conformity?
All required EAC certificates of conformity in Russia are entered into the EAC Certificate of Conformity Register on ROSAKKREDITATION **, where the current information and status of the EAC Certificate of Conformity are displayed
Is it necessary to keep a case file in the case of an EAC declaration of conformity?
Definitely needed, this is a mandatory requirement of the Technical Specifications of the Customs Union (TR CU).
Is it necessary to sign the EAC Declaration of Conformity separately with the EDS electronic key and upload it to the information repository of the Certification and Accreditation Center, including the electronic sample of the test report and other evidentiary materials?
The Accreditation Service of the Russian Federation shares private information about the applicant's company that it learns from FAU NIA. As a result, the EDS e-Key is only signed once when the EAC declaration is issued. With this data in mind and based on our own position, we believe that applicants can additionally authenticate copies of uploaded documents by any means, including EDS electronic keys. However, if all uploaded documents are certified only once at the time of issuance of the EAC Declaration and no additional verification of individual documents and information, this is in line with the requirements of the National EAC Declaration of Conformity Certification Scheme Registration Procedure Provisions.
About the Falsification of Sample Clearance Cargo Declaration (GTD).
A cargo declaration (DT) that is not worth falsifying samples. In the registration system FGIS under the EAC Certificate of Conformity (EAC COC), the number of the sample cargo declaration DT is entered, and the DT itself cannot be **. In addition, in the Registered Attraction FGIS under the EAC Certificate of Conformity (EAC COC), enter a scanned copy of the date and location of sampling and the act of sampling. Therefore, when controlling the EAC Certificate of Conformity (EAC COC), the state control authority opens the customs FCS database with the DT number of the sample clearance declaration to see the date and quantity (and the place of sending) in the sample cargo clearance DT. The date, location, and number of sampling actions can be seen by the national regulatory authority in the registration and certification system FGIS. In the event of falsification of sample clearance documents, EAC Certificate of Conformity may become invalid. Testing protocols and testing laboratories can also be accused of being unreliable.
What should I do if my EAC Certificate of Conformity is suspended by Rosakkreditation?
Is it possible to reinstate after revocation?
In order for the EAC Certificate of Conformity (COC) not to be suspended for non-implementation of Inspection Controls (ICs), the EAC Certificate of Conformity must be transferred to another Certification Body (CB) and annual surveillance control ICs must be performed.
In order to perform the annual surveillance inspection IC under this EAC Certificate of Conformity, a certification contract must first be concluded with another Certification Body (CB) and on this basis, the EAC Certificate of Conformity (EAC CoC) must be transferred to another Certification Body.
The Certification Body (CB) develops an inspection control plan; The certification center and the applicant carry out inspection controls; The certification center makes decisions on the results of inspection controls and the issuance of EAC certificates of conformity; The certification authority will enter the inspection control information into the Certification and Accreditation Authority's server registration system, the FGIS.
We do not recommend renewing EAC certificates that have been suspended by the Russian Federal Accreditation Service.
Therefore, there is no guarantee that the EAC Certificate of Conformity (EAC COC0) will not be terminated or found invalid, even if all certification procedures for the transfer of the EAC COC and the implementation of the annual factory surveillance audit IC have been completed and fees have been paid.
At the same time, if the EAC Certificate of Conformity (EAC COC) and the Annual Supervision and Inspection IC are officially handed over to another certification body very quickly, the Russian State Accreditation Service will find that the company has too little time to carry out these formalities. In this way, both EAC Certificate of Conformity (EAC COC) holders and institutions may be in trouble.
You can try to transfer the EAC Certificate of Conformity (EAC COC) to another certification body for the annual surveillance control IC and enter the annual surveillance inspection IC data into the Certification and Accreditation Authority (COC status is not involved). After that, it is necessary to write to the Russian Certification and Registration Service with a request to extend the validity of the EAC Certificate of Conformity, stating that the certificate applicant did not carry out an annual surveillance inspection of the IR before the suspension, but carried out an annual surveillance inspection after the suspension of the control IR and entered the results of the IR supervision into the registration system FGIS of the Certification and Accreditation Authority. The Russian Accreditation Agency will make a decision on the results of the suspension of the EAC Certificate of Conformity (COC).
How to apply for a certificate of certification for spare parts imported for the repair and maintenance of previously imported equipment?
Is it necessary to register the product as a spare part at the same time as the submission of all certificates, or is it necessary to draw up a notification, as provided for in Decision No. 130 of the Council of the Eurasian Community of November 12, 2021 on the procedure for the import of products for conformity assessment?
How and by whom can control the accuracy of the information provided? What are the consequences for program participants if they make a mistake in selecting a certificate?
In accordance with Decision No. 130 of the Council of the Eurasian Community of November 12, 2021, the import of spare parts is subject to the following rules:
The importing company of the spare parts used for the repair shall be the importer of the repaired product and the EAC Declaration of Conformity. Within the scope of Russian Decision No. 294), spare parts imported without authorization from a certification body (correct certification letter) must be imported in specific batches and quantities for repair purposes. According to Russian Decision No. 130, each customs clearance must be carried out in a specific quantity and with a letter of certification.
When importing a specific product for repair, an authorization document is not required, whereas when importing it for sale, an authorization document is required. The notification provided for in Russian Decision No. 130 is a requirement for the attached documentation. Earlier, in accordance with Russian Decision No. 294, at the request of customs, intermediaries undertook that the goods were imported for repair purposes. Therefore, there are no particular changes.
The customs or the operational units of BEP and PC, during customs control, check the documents and determine whether the importer has complied with the conditions of import of goods and the requirements of Decision No. 130.
If the event of the sale of imported spare parts for repair is true, sanctions are imposed on the applicant. Penalties will also be imposed if the importer of spare parts is not the authorizer and importer of the repaired product.
Therefore, we inform you that importers importing and selling goods of the above categories must carry out mandatory EAC certification, must comply with the requirements of the Technical Regulations of the Customs Union and be accompanied by an EAC certificate.
If an importer imports a product for sale in the name of spare parts without an EAC certificate, the Council may draw attention to the fact that the importer is not a qualified applicant for repairing the product and is not its importer.
We would like to remind you that in accordance with Russian Decision No. 130, it is mandatory to provide information on the import and sale of products repaired by spare parts EAC Certificate of Conformity or EAC Declaration of Conformity! We strongly recommend that you strictly comply with the provisions of the decision, and all imported spare parts are used by the importer for repairs and should not be given to third parties.
Is it possible to take samples from finished goods warehouses in Russia (RF) (without importing samples) to get a new batch of EAC Certificate of Conformity (EAC CoC)?
Yes, but with one caveat:
Samples can be taken at warehouses of finished products on the territory of the Russian Federation, and individual audits of the production status can be conducted. In this case, it is necessary to correctly draft the sampling act - which will be the main document - to answer"Why are the samples not imported?
When issuing an EAC Certificate of Conformity (EAC COC), it should be indicated:"Samples were not imported"and include the act of sampling in the EAC Certificate of Conformity, which clearly states that the sample was taken in a warehouse in the Russian Federation, at the address at the time, by one person or another.
But! Sampling and testing alone is not sufficient, and a certification body (CB) is required to identify all applied products to confirm their sample information, including declaration information. The selection (identification) behavior must reflect all product items in the new EAC Certificate of Conformity (application). This is important to comply with the conditions for the implementation of the EAC Certificate of Conformity (EAC COC) and to document that the EAC Certificate of Conformity (EAC COC) does not contravene.
Sampling and selection of samples can also be carried out at the warehouse of an authorized person of a foreign manufacturer in the territory of the Russian Federation, provided that there is a type of product for which the certification is applied for - not only the products from which the standard samples will be selected, but also all the applied products, which will be identified with the applied products, from which the specialists will determine the products from which the standard samples will be selected during the selection of samples!
How to postpone the annual surveillance control by 6 months?
The applicant prepares and sends a letter to the certification body requesting consideration of the possibility of postponing the EAC Certificate of Conformity inspection control for a period of 6 months (or less), stating the reasons (free form);
The accreditation body considers the application letter and, on this basis, makes a decision to postpone the inspection control;
The certification body enters information and inspection control extensions into the Certification and Accreditation Authority's registration system, FGIS.