Suspension of EAC Certificates

In April 2021, a draft regulation from the Russian government regarding the procedure for the suspension, renewal, and termination of EAC certificates and EAC declarations was presented. The document is expected to come into force on June 21, 2021, with the exception of certain provisions that will only be applied later – on September 1, 2021. 

The regulations of the document divide the powers among the state control authorities. Certification service providers remain responsible for the EAC certification of products, while applicants are responsible for the EAC declaration of goods. 

Registration of EAC Declarations

The provisions of the Ministry of Economic Development of the Russian Federation N478 have been integrated into the order of registration of EAC declarations. The new project includes some refinements, such as those concerning GLN codes. 

If information about GLN codes is not available, the supervisory authorities must be informed. Furthermore, an alternative identification method for the company must be found that allows for the localization of the production site. 

If such a location identifier does not exist, the geographical coordinates of the production site according to the Global Navigation Satellite System GLONASS must be provided.

Suspension by the Supervisory Authorities

The state control authorities are authorized to decide on the suspension of the EAC certificate / EAC declaration in the following cases:

• Identification of discrepancies between products and documentation
• Absence / non-fulfillment of the suspension of the EAC approval
• Absence of documentation for quality verification
• Absence of test reports for quality verification

In the event of non-compliance with violations that were the reason for the suspension of the EAC certificate / EAC declaration, the state control authorities are authorized to make a decision on the termination of their validity:

• Non-compliance with mandatory safety requirements
• False information about the applicant / manufacturer of goods
• Unreliability of information and documents
• Issuance of the EAC approval without compliance with legal regulations

Suspension by Rossakkreditatia 

Rossakkreditatia is authorized to make a decision on the suspension of the EAC certificate / EAC declaration for the following reasons:

• Non-compliance with the information contained in the unified register
• Identification of invalid EAC approval documents
• Issuance of an EAC approval based on invalid documents
• Conducting tests in an unsuitable testing laboratory 

In the section on individual solutions for the suspension of EAC certificates and EAC declarations, several cases are presented:

• Issuance of EAC certificates based on tests conducted using unsuitable testing methods.
• Issuance of EAC certificates based on a test that was declared invalid by the decision of Rossakkreditatia.
• The absence of information regarding the conduct of inspection controls within legal deadlines.
• Issuance of EAC certificates by a certification service provider that is not appropriately accredited.
• Issuance of EAC certificates based on test results that were not fully conducted.

Suspension by the Certification Service Provider

The certification service provider has the right to suspend the EAC certificate in the following cases:

• If the products endanger the safety of life or health of people, animals, or plants, or the property of the environment.
• If the products do not meet the safety requirements of the technical regulations of the Eurasian Economic Union.
• If there are negative inspection results or the applicant refuses to conduct the inspection control.
• Liquidation of the organization of the applicant or the manufacturer or withdrawal of products from serial production at the initiative of the applicant.
• Receipt of an order from the state control authority or Rossakkreditatia regarding the necessity of suspending the EAC conformity certificate.
• If there are changes in the production technology or if the evidence for the certification of the management system is not available.

Please note the important requirements in the project: The validity of the EAC conformity certificates and the EAC conformity declarations is considered suspended, renewed, or terminated from the day of entry of the relevant information into the unified certification register of Rossakkreditatia.