EAEU ROHS consulting

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

Most everyday household, as well as some professional products are covered by this regulation: audio, video equipment, servers, monitors, modems, cables, ticket printers, vending machines, etc. Among others, toys, medical devices, vehicules, measurements tools and instruments are out-of-scope.

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.  However, restricted phthalates under the EU RoHS are not in the scope of the EAEU one.

The obligation to comply with EAEU RoHS, sometimes called Russia RoHS, comes 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).

• 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 an Europe RoHS Declaration of Conformity (DoC), the bill of materials (BOM), manufacturers ISO certificates, 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.