Russian RoHS and Self-Certification

Question: Under the Russian version of the Restriction of Hazardous Substances (RoHS) Directive, is self-certification sufficient or do I need to perform lab testing on my product and its components?

Answer: For Russia RoHS (technically "Eurasian Economic Union 037/2016 On restriction of the use of certain hazardous substances in Electrical and Electronic Equipment"), confirmation assessment procedures are carried out by the applicant on the basis of their evidence. Testing can be carried out in the manufacturer’s laboratory.

Declarations of conformity must be accepted by the manufacturer’s local representative in the Eurasian Economic Union (EAEU), and the Eurasian Conformity mark (EAC) should be applied.

Note that additional electrical regulations may apply, depending on the product type. In these cases, an EAEU Certificate of Conformity (CoC) and Declaration of Conformity (DoC) may be required. The main difference between these documents is that the CoC must be conducted by a third party, while a DoC may be accepted on the merit of its own evidence.

In summary, for Russia RoHS, self-testing and documentation is acceptable, but other electrical regulations may require third-party involvement and testing. Similar to how the European CE marking covers the EU RoHS Directive and, depending on product type, also covers other CE marking laws (e.g. Electromagnetic Compatibility Directive, Radio Equipment Directive, Low Voltage Directive).

Content is current as of 2019-10-25.

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