Short Description: A German manufacturer planned to export electronic appliances to the Eurasian Economic Union. This case study explains how the EMC requirements were assessed, product variants were grouped and the EAC Certificate under TR CU 020/2011 was obtained.
A German manufacturer of electronic kitchen appliances planned to establish long‑term sales in Kazakhstan, Belarus and other countries of the Eurasian Economic Union. Shortly before the first shipment, the importer identified an important issue: the existing CE Declaration of Conformity and European EMC test reports were not sufficient for customs clearance and market access in the EAEU.
The products required an EAC Certificate under TR CU 020/2011 on the electromagnetic compatibility of technical equipment. At the same time, it was necessary to determine whether additional Technical Regulations of the Eurasian Economic Union applied.
The project was more complex than initially expected. Several product models, different power supplies, multiple firmware versions and incomplete technical documents had to be combined into a consistent EAC certification concept.
Initial Situation
The client was a medium‑sized German manufacturer producing electronically controlled kitchen appliances for household use.
The appliances included:
- Electronic speed control
- Digital control panel
- Switching power supply
- Electric motor
- Temperature monitoring
- Wireless module in selected models
Four product models were intended for export to the EAEU. All appliances were manufactured at the same production site and based on a common technical platform. The main differences involved motor output, control interfaces and individual convenience functions.
The manufacturer originally assumed that an existing European EMC test report could be used directly for EAC certification. However, the initial assessment showed that the technical documentation did not fully correspond to the requirements of TR CU 020/2011 and the applicable standards.
What Is TR CU 020/2011?
TR CU 020/2011 is the Technical Regulation of the Customs Union on the electromagnetic compatibility of technical equipment. It entered into force on February 15, 2013 and applies throughout the Eurasian Economic Union.
The member states of the Eurasian Economic Union are:
- Armenia
- Belarus
- Kazakhstan
- Kyrgyzstan
- Russia
TR CU 020/2011 is intended to ensure that electrical and electronic equipment does not generate unacceptable electromagnetic interference. At the same time, products must provide sufficient immunity against electromagnetic disturbances from their environment.
In simple terms, an electrical or electronic device must not interfere with other equipment and must continue to operate safely and reliably under its intended operating conditions.
Official information on the regulation, its amendments and the applicable lists of standards is published by the Eurasian Economic Commission.
EAC Certificate or EAC Declaration for EMC?
Not every product within the scope of TR CU 020/2011 automatically requires an EAC Certificate. Depending on the product category, conformity must be confirmed by either EAC certification or EAC declaration.
TR CU 020/2011 requires mandatory certification for certain groups of electrical and electronic products. These may include specific household appliances, computers, electric tools, electronic musical instruments and certain lighting products.
Technical equipment that falls within the scope of the regulation but is not included in the certification list is generally subject to EAC declaration.
In this case, the product classification showed that an EAC Certificate was required for the kitchen appliances. The assessment also identified additional Technical Regulations that had to be considered.
Which Additional EAC Regulations Applied?
EMC certification should not be considered in isolation. Electrical and electronic products can be subject to several EAEU Technical Regulations at the same time.
The following regulations were relevant to the kitchen appliances:
- TR CU 020/2011 - Electromagnetic Compatibility of Technical Equipment
- TR CU 004/2011 - Safety of Low‑Voltage Equipment
- TR EAEU 037/2016 - Restriction of Hazardous Substances in Electrical and Electronic Equipment
The requirements of TR CU 004/2011 and TR CU 020/2011 could be covered by a combined EAC Certificate. A separate EAC Declaration was required under TR EAEU 037/2016.
This combination is common for electrical and electronic equipment. However, the applicable regulations must always be determined individually based on the product design, technical characteristics and intended use.
The Main Challenges
The technical assessment identified three issues that had to be resolved before the EAC certification application could be submitted.
Different Power Supplies
Two of the models were equipped with a slightly different switching power supply. Although the housings and operating functions were almost identical, the alternative power supply could affect the electromagnetic characteristics of the complete appliance.
The different power supply versions therefore had to be clearly documented and considered when selecting the test samples.
Multiple Firmware Versions
The manufacturer had updated the control software several times during product development. Not every firmware update affected the EMC characteristics of the products. Nevertheless, it was necessary to document which firmware versions were included in the certification.
Inconsistent Model Designations
The manufacturer already had several European test reports. However, some of the model designations in those reports did not correspond exactly to the names used on the rating plates and in the sales documentation.
Without a clear technical assignment, the EAC certification body would not have been able to reliably evaluate the existing reports.
Developing the EAC Certification Strategy
The first step was to record all product variants in a certification matrix.
The following characteristics were compared:
- Model designation
- Commercial product name
- Motor output
- Rated voltage and frequency
- Power supply
- Control electronics
- Wireless functions
- Housing design
- Manufacturing site
- Firmware version
Based on this comparison, the four models could be grouped into one product family. This was possible because the technical differences were clearly documented and sufficiently covered by the planned tests.
The model with the highest motor output and the most extensive electronic equipment was selected as the representative test sample. Additional evidence was required for the alternative power supply.
This approach prevented the need to complete an entirely separate certification procedure for each individual model.
Documents Required for the EAC Certificate
The manufacturer provided the following documents for the certification procedure:
- Technical data sheets
- Operating manual
- Product descriptions
- Circuit diagrams
- Bills of materials
- Product photographs
- Draft rating plates
- Manufacturing site information
- Existing CE Declaration of Conformity
- European EMC and electrical safety test reports
- Overview of all product models
- Information about power supplies and electronic components
- Quality management documentation
Part of the technical documentation had to be prepared in Russian for the EAC certification procedure. It was particularly important to use consistent model designations and technical specifications throughout all documents.
EMC Testing of the Products
Product samples were tested by an accredited laboratory. The assessment focused on two principal areas: electromagnetic emissions and immunity.
Electromagnetic Emissions
The laboratory assessed whether the appliances generated electromagnetic interference that could affect other electrical or electronic equipment.
Depending on the product and test configuration, the assessment included:
- Conducted emissions
- Radiated emissions
- Harmonic current emissions
- Voltage fluctuations
- Flicker
Electromagnetic Immunity
The immunity tests assessed whether the appliances continued to operate as intended when exposed to external electromagnetic disturbances.
The tests included exposure to:
- Electrostatic discharge
- Electrical fast transients
- Surge voltages
- Radio‑frequency electromagnetic fields
- Conducted radio‑frequency disturbances
- Voltage dips
- Short interruptions
During the initial assessment, one model showed increased conducted emissions. The alternative switching power supply was identified as the cause.
The manufacturer worked with its supplier to provide a technically equivalent power supply with an improved input filter. After the modification, the relevant EMC test was repeated and successfully completed.
Role of the EAEU Authorized Representative
A manufacturer located outside the Eurasian Economic Union generally cannot act as the applicant for an EAC Certificate.
The applicant must be a legal entity or individual entrepreneur registered in an EAEU member state. Depending on the distribution structure, this can be:
- A subsidiary of the manufacturer
- An importer
- A distributor
- An authorized representative based in the EAEU
An EAEU authorized representative was appointed for this project. The representative’s duties, responsibilities and authority were defined in a formal agreement.
Selecting the applicant is an important strategic decision. If an EAC Certificate is registered exclusively in the name of a particular importer, the manufacturer may become dependent on that business partner. A future change of importer or distributor can then create legal and commercial difficulties.
EAC Certification of Serial Production
The manufacturer planned to supply the products to the EAEU over several years. For this reason, an EAC Certificate for serial production was selected.
The certification process included:
- Review of the technical documentation
- Identification and selection of representative product samples
- Laboratory testing
- Assessment of the manufacturing process
- Preparation of test reports
- Review of product marking
- Registration of the EAC Certificate
After successful completion, an EAC Certificate was issued for the defined product family. The certificate identified the covered models, manufacturer, production site, applicant and applicable Technical Regulations.
Depending on the certification scheme and the results of the conformity assessment, an EAC Certificate for serial production can generally be issued for up to five years.
Periodic inspection control may be required during the certificate’s validity period.
EAC Marking After Certification
Once the EAC Certificate had been issued and registered, the manufacturer was permitted to apply the EAC conformity mark to the covered products.
The EAC marking had to be applied before the products were placed on the market in the Eurasian Economic Union. It was included on the rating plate and in the accompanying product documentation.
The model designations shown on the rating plate also had to correspond exactly to the information stated in the EAC Certificate.
The EAC mark must not be applied as a precaution or while the certification procedure is still in progress. It may only be used after the required conformity assessment has been successfully completed.
Result of the Project
The EAC Certificate was registered for all four intended product models. The manufacturer did not need to complete a separate certification procedure for every individual model.
The structured product‑family approach made it possible to:
- Avoid duplicate product testing
- Document technical differences transparently
- Include different power supply versions correctly
- Standardize model designations
- Reduce questions from the certification body
- Establish the basis for future serial deliveries
After registration of the EAC Certificate and the additional EAC Declaration under TR EAEU 037/2016, the manufacturer was able to prepare the first shipment to the Eurasian Economic Union.
Lessons for Manufacturers
This project demonstrates that CE marking does not automatically confirm EAC compliance. European EMC reports can provide a valuable technical basis, but they must be assessed for their suitability within the applicable EAC conformity procedure.
When several product models are involved, the product family should be analyzed before representative samples are selected. Differences involving power supplies, motors, electronic controls, enclosures or wireless modules can significantly affect electromagnetic compatibility.
An early technical assessment reduces the risk of:
- Selecting unsuitable test samples
- Excluding relevant models from the certificate
- Having existing test reports rejected
- Applying incorrect EAC marking
- Delays during customs clearance
- Additional testing and certification costs
Conclusion
The EAC Certificate under TR CU 020/2011 confirms that technical equipment meets the applicable requirements for electromagnetic compatibility. For manufacturers of electrical and electronic products, it is often an essential requirement for market access in Russia, Kazakhstan, Belarus, Armenia and Kyrgyzstan.
In this case, laboratory testing alone was not sufficient. Correct product classification, grouping of the models, coordination of the technical documentation and appointment of a suitable EAEU applicant were equally important.
A carefully planned certification strategy allowed all relevant models to be covered while avoiding unnecessary duplicate testing and delays.
EAC Certification Support from AC Inorms GmbH
AC Inorms supports manufacturers throughout the EAC certification process under TR CU 020/2011.
Our services include:
- Assessment of EAC certification requirements
- Identification of applicable EAEU Technical Regulations
- Classification of products and model variants
- Preparation and review of technical documentation
- Coordination of product testing
- Organization of the EAEU authorized representative
- Communication with certification bodies and laboratories
- Support with EAC marking
- Preparation of EAC Certificates and EAC Declarations
For an initial assessment, manufacturers should provide a product description, technical specifications, intended use, existing test reports and an overview of all models intended for export.
An EAC Certificate is an officially registered document confirming that the listed technical equipment complies with the electromagnetic compatibility requirements of TR CU 020/2011.
The certificate is generally valid in all member states of the Eurasian Economic Union: Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia.
No. CE marking does not replace an EAC Certificate or EAC Declaration. Existing European test reports may be considered during the technical assessment if they are suitable, complete and sufficiently up to date.
No. Depending on the product category, TR CU 020/2011 may require an EAC Certificate, an EAC Declaration or no conformity assessment under this particular regulation. Each product must be classified individually.
The applicant must generally be a company or individual entrepreneur registered in the Eurasian Economic Union. The applicant can be an importer, distributor, local subsidiary or authorized representative of the foreign manufacturer.
An EAC Certificate for serial production can be issued for up to five years, depending on the certification scheme. Certificates issued for a particular batch or single product apply only to the products specified in the certification documents.
Suitable evidence of conformity is required for EAC certification. The required tests and the possibility of using existing reports depend on the product, certification scheme and assessment performed by the responsible certification body.
Yes. Technically comparable models can often be combined in a single certificate. Their differences must be clearly documented and covered by the selected samples and test reports.
Electrical components, machinery and industrial equipment may fall within the scope of TR CU 020/2011. Whether certification or declaration is required depends on the product design, intended use and classification.
The cost depends on the product type, number of models, required laboratory tests, certification scheme, intended validity period and quality of the available documentation. A reliable quotation can normally be prepared only after an initial technical product assessment.
