Testing in Customs Union compliance certification
As required by the Customs Union, product groups are subject to the applicable dedicated technical regulations of the Customs Union (sometimes, a product is subject to a number of regulations), which lay down the available certification schemes and their components as applicable. The last word in choosing the certification scheme rests with the applicant themselves, but the certification authority may deny safety validation, giving reasons for the unsuitability of the scheme.
All the statutory certification schemes of the Customs Union are approved under Customs Union Commission Decision No. 621 of 7 April 2011.
Certification schemes requiring product testing
The certification of products subject to the Technical Regulations of the Customs Union requires testing under the following schemes:
- 1s and 2s, for mass-produced products;
- 3s, for a batch of products;
- 4s, for the release of a single item.
Note also schemes 7s and 8s, which are used for mass production certification and provide for type assessment. Such schemes are only suitable for the certification of:
- sophisticated products;
- products with a large number of variations planned.
For sophisticated products, investigation is made of a production prototype, which is accepted as a standard sample for all future products.
Alternatively, where variants are planned during the production cycle, a review shall be conducted of technical documentation for the products and testing of standard samples or their critical components.
Products requiring a test report
Certification of conformance without testing is not available for the following products:
- low-voltage electrical equipment under schemes 1s, 3s or 4s (pursuant to TR CU 004/2011 and TR CU 020/2011);
- gas burners under schemes 1s, 3s or 4s (pursuant to TR CU 016/2011);
- explosion-proof equipment under schemes 1s, 3s or 4s (pursuant to TR CU 012/2011);
- pressure vessels under schemes 1s, 3s, 4s or 7s (pursuant to TR CU 032/2013);
- lift equipment under schemes 1s, 3s or 4s (pursuant to TR CU 011/2011);
- children's products under schemes 1s, 2s, 3s or 4s (pursuant to TR CU 007/2011);
- toys under schemes 1s, 2s or 3s (pursuant to TR CU 008/2011);
- consumer goods under schemes 1s, 2s or 3s (pursuant to TR CU 017/2011).
Product certification under test-free schemes
Certification of conformity with to the Technical Regulation of the Customs Union without testing is available under schemes 5s or 6s. In this context, both schemes are only suitable for the certification of mass-produced products where it is impossible to fully evaluate the finished product.
In lieu of testing, the certification authority shall conduct a study of the product design, which involves a review of:
- technical documentation for the manufacture of products;
- the results of engineering analysis;
- the results of tests on experimental samples.
Mandatory certification without testing is also available under scheme 9s, which is suitable for a product batch. In this case, a certification decision shall be made based on the results of a review of the technical documentation, which includes all materials directly or indirectly evidencing the safety of products.
An additional factor in choosing certification scheme 9s is that a seller or importer is not eligible as an applicant unless they have an agent within the Customs Union (otherwise, certification of a batch of goods does not require an agent).
Products that can be certified without testing
Test-free certification is available under scheme 5s or 6s for two product groups:
- personal protective equipment (pursuant to TR CU 019/2011);
- pyrotechnic devices (pursuant to TR CU 006/2011).
As for certification scheme 9s, it can only be used currently for a batch of machinery and equipment designed for industrial applications within the Customs Union. This is stipulated in the dedicated regulation TR CU 010/2011.
Product testing in the context Customs Union conformity declaration
Product testing as a condition for the registration of declaration of conformity to the Technical Regulations of the Customs Union is contingent on the terms of the declaration scheme chosen. In all, six schemes are in place (Customs Union Commission decision No. 621 of 7 April 2011, Clause 23 of the schemes policy, Appendix G [D]): 1d and 2d, 3d, 4d, 5d and 6d.
Schemes 1d, 3d, 5d and 6d are applicable to the declaration of mass-produced products, and schemes 2d and 4d, to that of a batch / single item.
Note that the applicability of each of the six schemes is defined in the dedicated regulation covering the products involved.
A detailed review of the applicability of each CU TR declaration scheme is available here.
The Customs Union regulations allow the registration of declaration of product conformity without product testing under scheme 5d only. In lieu of testing of finished products, the scheme provides for type assessment of future products.
The term “type assessment” means a review of the production prototype as a reference representative of all future products. Type assessment can also involve a review of technical documentation.
The scheme is only available for the declaration of the following product groups:
- packaging materials, as per TR CU 005/2011, “On packaging safety”;
- pyrotechnic products, as per TR CU 006/2011, “On the safety of pyrotechnic products”;
- machinery and equipment, as per TR CU 010/2011, “On the safety of machinery and equipment”;
- pressure vessels, as per TR CU 032/2013, “On the safety of pressure vessels”.
NB: Type assessment is conducted by the product certification authority or an accredited testing laboratory!
Product test-based declaration
The remaining five declaration schemes all require product testing. There are differences between laboratories in this context: under some schemes, the declarant is entitled to verify the conformance to the safety ratings specified; under others, the studies must be conducted by an accredited centre without fail.
E.g., declaration based on in-house safety cases is available under schemes 1d and 2d. The involvement of an independent party is required under schemes 3d, 4d and 6d.
In this context, most product groups are not required under the technical regulations of the Customs Union to follow a specific scheme: the applicant is given discretion in the choice. Except for perfume and beauty products ( TR CU 009/2011, “On the safety of perfume and beauty products”), meat and meat products ( TR CU 034/2013, “On the safety of meat and meat products”), which prohibit registration of a declaration without testing by an accredited laboratory. On the other hand, for lubricants subject to TR CU 030/2012, “On the requirements for lubricating materials, oils and special liquids”, only schemes without the involvement of an independent partycanbe used.