Certificate or declaration: how to understand what your product needs

Both a certificate and a declaration confirm the same thing — that the product meets the requirements of the technical regulation. What differs is the procedure, the responsibility and the cost of a mistake. Here is the fork, step by step.

In short: what is the difference

How the form is determined: four steps

Example: LED lamps for home

HS code (TN VED) — 9405 40 990 0. Regulations: TR CU 004/2011 "On safety of low-voltage equipment" and TR CU 020/2011 "Electromagnetic compatibility of technical equipment". The form is a declaration under scheme 1D, based on the test report of an accredited laboratory.

If the product falls under several regulations, you need documents for each of them. One document "for everything" is the most common mistake of beginners.

When nothing is needed

Some products are not covered by the EAEU technical regulations: stationery, some kinds of jewelry, certain categories of household goods. In this case counterparties and marketplaces ask for a letter of non-applicability — an information document confirming that mandatory conformity assessment is not required. Formally it is not a permit document, but without it a listing on a marketplace may not be accepted.

Typical errors

What to check before issuing

• The HS code (TN VED) is determined by purpose and materials, not by appearance
• All regulations that apply to the product are found
• It is checked whether the product is in the lists that require certification
• The name of the product is the same in all documents
• The chosen laboratory has a valid accreditation certificate and a suitable scope of accreditation

How to speed it up

A manual check takes hours: find the code in the nomenclature, compare it with the product lists, determine the scheme, make sure the laboratory is valid. The platform does this in one session: you describe the product in plain words, and the system shows the code, the applicable regulations and the proposed form of assessment — every item is open for checking before the application is sent.

The decision to work on the application is always made by the accredited contractor: it is responsible for the issued document. How this part works — in the section for contractors.

A fork in three questions

Who can be the applicant

This question is clarified at the most inconvenient moment — when the documents are already issued to the wrong person. The applicant is not the one who pays for the issuing, but the one who, under the regulation, has the right to declare conformity.

The practical conclusion for those who buy from a distributor: a document issued to another company does not become yours automatically. You need either a confirmation of the right to sell from the holder of the document, or your own document for your batch.

Scheme: why its number is important

Every document has a scheme number — 1s, 3s, 4s, 1d, 3d, 6d. This is not a bureaucratic note: the scheme defines what exactly was checked, and therefore what the document covers.

• Schemes with the index "s" — certification. 1s — serial production with an analysis of production and later inspection control. 3s — a batch. 4s — a single item.
• Schemes with the index "d" — declaration. 1d and 2d rely on the applicant's own evidence, 3d and 4d require tests in an accredited laboratory, 6d — a certified management system.

A practical consequence: a document under a batch scheme cannot be attached to the next delivery, even if the product is the same. This is one of the most frequent complaints of marketplaces — the seller re-uses a batch document, and the marketplace compares the batch numbers.

Validity periods and what happens when something changes

The maximum period for serial production is five years, but the real period can be shorter: it is set by the certification body or the applicant, depending on the scheme. For a batch no period is set at all — the document is tied to a specific volume.

Something else is much more important than the period: the document stops describing the product before it expires. A reissue is needed if:

• the design, composition or materials have changed
• the production site has changed
• the name of the product or the model range has changed
• the details of the applicant or the manufacturer have changed
• the list of models that you import under this document has been extended

The last item is underestimated most often. The document covers the models and article numbers that are listed in it. A new modification that is not in the list is not covered by the document — formally it is imported without proof of conformity.

How to check a supplier's document

If you do not issue the document yourself but receive a scan from the supplier, all the work is the check. It takes five minutes and saves a batch.

• Find the document in the register by its number — do not rely on the scan: it is the picture that is forged, not the record
• Compare the name of the product with what is written on your packaging
• Check the manufacturer: is it the same plant as on the marking
• Look at the scheme: if it is a batch scheme, make sure your batch is included
• Check the list of models and article numbers
• Make sure the document is valid on the date of import, not only on the date of purchase
• Check the accreditation of the laboratory that issued the test reports

About the status separately: a document can be in the register but be suspended or terminated. This is visible in the register entry, but not in the scan you received. What to do if the document has been suspended, we explained in a separate article, and how to read the register — in the material about laboratory checks.