EAC Certification (TR CU 010/2011) for Machinery Safety: Comprehensive Guide
Introduction to TR CU 010/2011
TR CU 010/2011 "On Safety of Machinery and Equipment" is a crucial technical regulation established by the Eurasian Economic Union (EAEU) to ensure the safety of machinery and equipment throughout their lifecycle. This regulation applies to all stages including design, manufacturing, installation, commissioning, operation, storage, transportation, sale, and disposal.
The regulation was adopted on October 18, 2011, came into force on February 15, 2013, and replaced previous national standards like GOST in EAEU member states7. It aims to:
Establish unified mandatory safety requirements
Ensure free circulation of machinery within the EAEU customs territory
Protect life, health, property, and the environment
Scope and Applicability
Products Covered
TR CU 010/2011 applies to a wide range of machinery and equipment, defined as "a series of linked parts or components assembled to form a whole unit for a specific application (e.g., processing, transport, or packaging), where at least one part is powered by an energy source through corresponding drive mechanisms and control chains".
Specific products requiring EAC certification under this regulation include:
Agricultural machinery: Tractors, harvesters, livestock equipment
Construction equipment: Excavators, loaders, cranes
Mining equipment: Drilling rigs, ventilation systems, mining transport machines
Woodworking tools: Household woodworking machines, chainsaws
Industrial machinery: Metalworking machines, welding equipment
Material handling equipment: Conveyors, forklifts, lifting devices
Specialized equipment: Snowmobiles, garage equipment, catering machinery
Exemptions
The regulation does not apply to:
Machinery parts or spare parts (unless they're safety components)
Equipment for military purposes
Medical devices
Equipment for nuclear facilities
Certification Types and Modes
TR CU 010/2011 offers two main certification pathways based on product risk level:
1. EAC Certificate of Conformity (CoC)
Applicability: Required for high-risk machinery listed in Appendix 3 of TR CU 010/20111012. Examples include agricultural machinery, mining equipment, lifting devices, and woodworking machines10.
Key Features:
Mandatory sample testing in EAEU-accredited laboratories
Factory audit and quality management system assessment
Annual surveillance audits for batch production certificates
Valid for 1-5 years depending on certification scheme
Certification Schemes:
1C: For serial production (up to 5 years validity)
2C: For batch production
3C: For single batch/shipment
4C: For single product unit
9C: For limited quantity of machines for EAEU enterprises
2. EAC Declaration of Conformity (DoC)
Applicability: For medium-to-low risk machinery listed in Appendix 4 of TR CU 010/2011. Examples include turbines, diesel generators, conveyor belts, and metalworking machines.
Key Features:
Self-declaration by manufacturer/importer based on technical documentation
Generally no sample testing or factory audit required5
No annual surveillance
Valid for up to 5 years
Declaration Schemes:
1D-6D: Various modes based on production type and risk level
Table: Comparison of EAC Certificate vs Declaration for TR CU 010/2011
FeatureEAC Certificate (CoC)EAC Declaration (DoC)
ApplicabilityHigh-risk machineryMedium-to-low risk machinery
TestingMandatory laboratory testsUsually not required
Factory AuditRequiredNot required
Annual SurveillanceYesNo
ValidityUp to 5 yearsUp to 5 years
ApplicantAny legal entityOnly EAEU-registered company
ResponsibilityShared with certifying bodySolely on declarant
Certification Process
The EAC certification process under TR CU 010/2011 typically involves the following stages:
1. Product Classification
Determine applicable regulations using HS codes
Identify whether the product requires CoC or DoC based on TR CU 010/2011 appendices
2. Documentation Preparation
Required documents generally include:
Application form
Company registration documents
Detailed product description and specifications
Technical drawings and schematics
Risk assessment report (requires Russian notarization)1
Operation manuals in Russian
ISO 9001 certificate (if available)
Previous certifications (CE, CB, etc.)
Component lists with certificates
Product photos and nameplate images
3. Product Testing
Samples tested in EAEU-accredited laboratories
Tests vary by product type but typically include:
Mechanical safety (GOST ISO 12100-2013)
Electrical safety (GOST EN 60204-1-2018)
Pressure tests for hydraulic equipment
EMC tests (TR CU 020/2011)
Specialized tests (e.g., spray safety for agricultural equipment)
4. Factory Audit (For CoC)
On-site assessment of production facilities
Evaluation of quality management system
Verification of production consistency with submitted documentation
5. Certification Issuance
Certificate/declaration registered in Rosakkreditatsiya system
EAC mark authorization
Typical processing time:
CoC: 2-3 months (including testing and audit)
DoC: 1-5 working days (document review only)
6. Post-Certification
Annual surveillance audits for CoC
Market surveillance by authorities
Requirement to maintain technical documentation
Technical Requirements
Machinery must comply with various safety standards under TR CU 010/2011, including:
1. General Safety Requirements (GOST 12.2.003-2018)
Risk assessment and mitigation
Safety guards and protective devices
Emergency stop functions
Stability under operational conditions
2. Electrical Safety (GOST EN 60204-1-2018)
Insulation resistance
Grounding continuity
Protection against electric shock
IP rating appropriate for environment
3. Mechanical Safety
Structural strength (vibration, impact resistance)
Moving part protection
Load-bearing capacity
Safety factors for critical components
4. Additional Requirements
Depending on machinery type, other regulations may apply:
TR CU 004/2011: Low voltage safety89
TR CU 020/2011: Electromagnetic compatibility
TR CU 012/2011: Explosive atmosphere equipment
TR CU 032/2013: Pressure equipment9
EAC Marking Requirements
Upon certification, products must bear the EAC mark with specifications:
Minimum height of 5mm
Permanent attachment to product or packaging
Clear contrast with background
Placement on:
Each product unit (non-removable part)
Packaging (if product marking impossible)
Accompanying documents5
The mark indicates compliance with all applicable EAEU technical regulations.
Validity and Maintenance
CoC: Typically 1-5 years (scheme dependent)
DoC: Up to 5 years
Renewal: Process must be repeated before expiration
Changes: Product modifications may require recertification1
Special Considerations
1. Digital Certification
EAEU has introduced digital certification systems:
Electronic applications via GosUslugi platform
Digital document management requirements (2025 update)
2. Carbon Footprint Declaration
New requirement for heavy machinery from 2025
Carbon emission grading system implementation
3. Dynamic Traceability (2025 Update)
Technical documents require QR codes linking to EAEU database
Existing certificates must update documents by January 2026
4. Remote Audits
Pandemic-era allowance for remote factory audits
May reduce certification timeline and costs
Practical Recommendations
Start Early: Begin certification process 6-8 months before planned export
Technical Documentation:
Ensure compliance with GOST 2.104-2006 formatting
Prepare Russian translations of all documents
Maintain version control for updates
Partner Selection:
Work with EAEU-accredited certification bodies
Consider local representatives for smoother process
Product Modifications:
Document all changes from original certified design
Consult certification body before implementing changes
Market Surveillance:
Maintain quality consistency with certified samples
Keep records of production tests and inspections
Common Challenges and Solutions
ChallengeSolution
Complex DocumentationEngage professional certification consultants
Language BarriersUse certified translation services
Testing FailuresConduct pre-testing with manufacturers
Factory Audit IssuesImplement QMS before audit
Regulatory UpdatesSubscribe to EAEU regulatory updates
Costs and Timeline
Cost factors include:
Product complexity and risk level
Number of applicable technical regulations
Testing requirements
Certification scheme (CoC typically 2-3x DoC cost)
Need for local representation
Member State Recognition
EAC certification under TR CU 010/2011 is valid in all EAEU member states:
Russia
Belarus
Kazakhstan
Armenia
Kyrgyzstan
This eliminates the need for separate national certifications in each country.
Conclusion
TR CU 010/2011 EAC certification is a mandatory requirement for machinery entering the Eurasian market. Understanding its complexities—from product classification to testing requirements and ongoing compliance—is essential for successful market entry. With proper planning, documentation, and partner selection, manufacturers can navigate this process efficiently while ensuring their equipment meets all necessary safety standards.
The evolving regulatory landscape, including digital certification and carbon footprint requirements, underscores the importance of staying current with EAEU technical regulations. Professional guidance from accredited certification bodies can help streamline the process and avoid costly delays or non-compliance issues.
EAC Certification Body: Shanghai Jinghe Industrial Equipment Testing Co., Ltd.（上海经合工业）
