EAEU RoHS Compliance: A Roadmap for Electrical & Electronics Manufacturers Operating in Eurasia

The Eurasian Economic Union (EAEU) comprising Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia, has implemented strict regulations to ensure the safety and environmental sustainability of electronic and electrical products. Enacted on March 1, 2020, the Technical Regulation TR CU 037/2016 and TR EAEU 041/2017, commonly known as EAEU RoHS, restrict the use of hazardous substances, mirroring the European Union's RoHS Directive. In this blog, we will explore the intricacies of EAEU RoHS, from its scope and substances of concern to compliance requirements and the crucial Eurasian Conformity (EAC) Declaration of Conformity. EAEU RoHS also called as “Russia RoHS” or "EurAsia RoHS”.

Understanding EAEU RoHS Regulations

Scope of EAEU RoHS

Eurasian Economic Union (EAEU) RoHS applies to 12 categories of electrical and radio-electronic products:

• Household appliances and devices
• Electronic computers and devices connected to them.
• Telecommunication facilities
• IT equipment
• Lighting and office equipment
• Power tools
• Equipment for leisure and sports
• Venders and gaming machines
• Cash management equipment.
• Cable products
• Protective cutout devices (RCDs)
• Fire alarm systems.

Substances of Concern/RoHS material list in EAEU RoHS

The regulation targets six hazardous substances at the homogeneous material level:

• Cadmium
• Hexavalent Chromium
• Lead
• Mercury
• Polybrominated Biphenyls (PBBs)
• Polybrominated Diphenyl Ethers (PBDEs)

Each substance has a specific threshold, with cadmium restricted at 0.01% by weight and others at 0.1% by weight.

EAEU RoHS standards

The EAEU RoHS aligns with the European RoHS substances and thresholds, emphasizing compliance at the homogeneous material level. The six restricted RoHS substances include Cadmium, Hexavalent Chromium, Lead, Mercury, PBBs, and PBDEs.

Compliance with EAEU RoHS directive

Eurasian Conformity Mark (EAC)

• Compliance is mandatory, and manufacturers must affix the EAC mark to their products that meet compliance. Failure to comply may result in product removal from the market.

EAEU RoHS Certification Process

• Manufacturers or importers seeking EAEU RoHS certification must follow a meticulous process:
• Prepare a comprehensive technical file, including a RoHS test report or European RoHS Declaration of Conformity (DoC), bill of materials, ISO certificates, and a user guide in Russian.
• Utilize standard IEC 63000 for technical file preparation.
• Have the DoC signed by a local representative and submit it, along with technical documentation, to an accredited Certification Body in an EAEU Member State.

Publication in EAEU Database

The DoC of compliant products is published in a database managed by the EAEU, ensuring transparency and traceability.

Eurasian Conformity Mark Application

Compliant with RoHS directive ensures the affixing of the EAC mark to products, signifying adherence to EAEU RoHS standards.

Conformity Assurance in Eurasian RoHS:

• Testing by In-Country Laboratories:

• Electronic product manufacturers can choose to have their products tested by in-country laboratories within the Eurasian Economic Union (EAEU). These labs conduct physical assessments to ensure compliance with substance restrictions.

● Demonstration of Technical Documentation:

• Manufacturers may opt for demonstrating conformity through technical documentation aligned with international standards like IEC 63000 or EN 50581. This includes a RoHS test report, a European RoHS Declaration of Conformity (DoC), a bill of materials, ISO certificates, and a user guide in Russian.

Eurasian RoHS Enforcement:

• Market Surveillance:

• Regulatory bodies and authorities in EAEU member states conduct market surveillance to verify product compliance. This involves checks for the EAC mark, review of technical documentation, and random product testing.

• Customs Officers at Borders:

• Customs officers inspect products at borders to ensure that necessary records are on file. This includes checking for the EAC mark and verifying the submission of required technical documentation by manufacturers.

Conclusion

EAEU RoHS compliance is essential for companies operating in Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia. The regulations, akin to the EU RoHS Directive, underscore the region's commitment to environmental responsibility and consumer safety. Manufacturers and importers must embrace the certification process, demonstrating their dedication to sustainable practices. As EAEU regulations evolve, staying informed and proactive in maintaining a sustainable supply chain management is pivotal for continued success in this dynamic regulatory landscape.