EAEU ROHS CONSULTING

The Eurasian Economic Union (EAEU) between Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia has enacted the Technical Regulation TR CU 037/2016 on the restriction of use of hazardous substances (RoHS) in radio and electronic devices, requiring product testing or assessment.

This regulation (TR CU 037/2016) was implemented based on the European RoHS Directive and follows compliance processes similar to the European standard EN 50581 (now replaced with IEC 63000). The latter is “Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances”.

Products of Interest for EAEU RoHS

Within the scope of this regulation are the following products:

Refrigerators, washing machines, air conditioners, vacuum cleaners, and other household electric items;
PCs, laptops, tablets, printers, routers, and other similar devices;
Telecommunication products such as phones, fax machines, and radios.
Drills, electric saws, and welding machines;
Luminaires and lights;
Electric musical instruments;
Gaming machines;
Cables;
Switches;
Fire alarms;
Etc.

Outside the regulation’s scope are the following products:

Unless otherwise specified in Appendix N 1 to this technical standard, electrical devices and radio electronics with a rated voltage of more than 1000 V AC and 1500 V DC;
Electrical devices, not listed in Appendix N 1 of this technical standard,that are intended primarily for use as components of electrical equipment;
Electric toys;
Photovoltaic panels (solar panels), which are used in electrical products and radio electronics.
Electrical devices for ground and space orbiting objects;
Equipment designed solely for use in air, water, land, and underground transportation;
Electric batteries and accumulators, including those introduced into circulation as part of electrical items on Union territory;
Second-hand electrical gadgets;
Measuring instruments;
Medical equipment.

Russia RoHS Rules

This Economic Union and the Eurasian Customs Union have agreed to restrict the same 6 first Europe RoHS substances at the homogeneous material level:

Cadmium
Hexavalent Chromium
Lead
Mercury
PBBs
PBDEs

The thresholds are the same too, 0.1% by weight except for cadmium which is restricted at 0.01% by weight. Note that phthalates restricted under the EU RoHS are not in the scope of the EAEU RoHS.

The obligation to comply with EAEU RoHS, sometimes called Russia RoHS, came into force on March 1st, 2020. A Eurasia REACH regulation is also being developed, covering a wide range of substances and mixtures (similar to EU REACH).

Eurasian Conformity Mark

Compliance as a producer is mandatory. Manufacturers who release their products into the market without compliance, will not receive a valid Eurasian Conformity – EAC mark on their products. No EAC mark means the product will be removed from the market.

How Do I Get a Russia RoHS Certification?

As a manufacturer or an importer, be ready to show evidence of a comprehensive technical file.

The technical documentation includes a RoHS test report or a Europe RoHS Declaration of Conformity (DoC), the bill of materials (BOM), manufacturers ISO certificates, a user guide in Russian, and a local representative agreement.

To prepare the technical file, the same approach as for EU RoHS is recommended, using standard IEC 63000.

The DoC must be signed by a local representative and submitted to an accredited Certification Body in one of the EAEU Member States, along with the technical documentation.

This approach is aligned with the EMC and Safety Approval process.

The DoC of your products is published in a database managed by the EAEU.

EAC mark the product.

Should you have any questions, don’t hesitate to contact Enviropass.

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