Many are the novelties that were introduced last year in relation to the certification process for the Eurasian Economic Union countries, the Russian Federation, Kazakhstan, Armenia, Belarus and Kyrgyzstan.
New constraints and mandatory laws applicable to specific product categories show an increased interest in standardisation by countries belonging to the Eurasian Customs Union.
New technical regulations will replace the respective Federal Laws of each member state, especially regarding fire safety certificate and chemical and dangerous substances in electrical and electronic equipment. The CUTR 043 regulation will come into force on 1st January 2020. So, how to be prepared for this change?
EAEU Regulations: what are the implications for fire safety products?
Among the EAC regulations introduced last year, along with the CUTR 037 and 041 regulations for dangerous and chemical substances, the CUTR 043 regulation undoubtedly deserves greater attention.
Within the framework of the new EAEU regulations, which were introduced in the Eurasian Economic Union countries, the CUTR 043 regulates fire safety products, such as fire-fighting material and equipment.
As of today, national regulations are still valid, such as the TR 123 for Russia. However, we are undergoing a transition period during which new regulations for the Eurasian Economic Union will come into force.
In particular, the fire safety certificate governed by the EAEU TR 043 regulation, will be valid from 1st January 2020.
Among product categories which the CUTR 043 technical regulation will apply to, we can find for example:
- Fire-fighting material
- Fire-fighting equipment
- Fire-fighting equipment (sensors, control panels and power supply)
- Technical devices operating as parts of fire-fighting systems (valves, compensators and filters)
- Fire-fighting PPE and clothes
- Evacuation devices and tools
- Doors and windows with fire-proof rating
- Other special categories
The full list of products included in the scope of the 043 regulation is available at this link.
As already mentioned, the EAEU TR 043 will soon replace the national fire safety regulations. For example, in Russia the CUTR 043 regulation will replace the TR 123. Old national certificates can be used until their expiration date, however not later than 1st July 2021. In addition, the 1st January 2020 is also the date from which it will be no longer possible to issue national certificates.
It should be noted that if a custom code is currently covered by a national certificate expiring before 1st January 2020, it would be preferable to wait for the entry into force of new EAEU TR 043, rather than renewing the national certificate.
For all products which are compliant with a national legislation, but aren’t compliant with the EAEU 043 yet, the regulation establishes that their production and distribution will only be possible until 1st July 2021. However, this regulation also requires that with a national certificate it will be necessary to renounce the possibility to affix the product with the EAC mark. If the product complies with the national legislation but does not comply with the new technical 043 regulation, the product can be marketed until 1st July 2021, but it won’t be EAC marked.
In case of certificates expiring by 31st December 2019, the approach we recommend following is to wait for the coming into force of the new CUTR 043 from 1st January 2020.
As for other EAEU regulations, the new CUTR 043 can be issued as a declaration or a batch or serial certification. In both cases it will have a validity of 5 years.
How to easily certify EAC according to CUTR 043
Starting from 1st January 2020 it will be possible to certify fire-fighting products only according to the new regulation, even though old certificates will be able to circulate until 1st July 2021.
The application of the Federal Law will be possible until 31st December 2019, however the fire-safety certificate, if issued or renewed, will be only valid until 1st July 2021. For this reason, it is advisable to wait for the 1st January 2020: according to the new CUTR 043, the EAC certification (or declaration) will be valid for 5 years starting from the date of issue.
As the new year is approaching, it is necessary to assess whether technical regulations that were previously applied are still applicable to the same product, or whether the carried out test reports will be still considered valid by the Certification Body.
If you already own an EAC certificate in compliance with the Federal Law 123, it will be possible to register the product according to the new 043 regulation by simply repeating the tests, prior to verifying that the specific product standards and the Certification Body have remained unchanged. It is an assessment that needs to be carried out on a case by case basis and processed well in advance compared to the date of the coming into force of the 043 standard, and with the technical support of an expert in order not to be without a certification for a long time.
In conclusion, the application scope of the new CUTR 043 regulation is very wide and will replace a set of pre-existing Laws, for example the TR 123 for Russia. The same will happen to the Federal Laws which are in force in other countries within the Eurasian Economic Union. This transition is the signal at community level that the Eurasiatic Union has moved towards an increased standardization, whose purpose is to overtake national regulations and manage the certification scheme at customs union level.
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