QUESTIONS RELATED TO:
Issues related to the technical regulations of the Eurasian Economic Union
QUESTION 1.
Hello. Is it possible, instead of the EAEU certificate of conformity for a product, to obtain a declaration of conformity, even if the CU regulation itself states that this product is subject to certification according to one or another scheme? If possible, what legal acts regulate this?
ANSWER 1.
Must not.
Relations in the field of conformity assessment are regulated by the Law of the Republic of Belarus dated 24.10.2016 No. 437-Z "On Conformity Assessment and Accreditation of Conformity Assessment Bodies" (hereinafter referred to as the Law) and other legislative acts, international legal acts constituting the law of the Eurasian Economic Union (hereinafter referred to as the Union).
In accordance with paragraph 3 of Article 23 of the Law, mandatory confirmation of conformity is carried out for the compliance of the objects of conformity assessment with the technical requirements of the technical regulations of the Republic of Belarus or technical regulations of the Union (Customs Union) or technical requirements contained in regulatory legal acts of the President of the Republic of Belarus or other legal acts in accordance with the procedure defined by him, providing for the introduction of mandatory confirmation compliance in connection with the need to take prompt measures of state regulation. At the same time, mandatory confirmation of conformity is carried out in the form of mandatory certification or declaration of conformity.
In accordance with paragraph 11 of Article 30 of the Law, the manufacturer or authorized by the manufacturer or the seller (supplier) has the right, instead of declaring the conformity of products, to choose to certify this product, if such an opportunity is provided for by the technical regulations of the Republic of Belarus, or by a regulatory legal act of the President of the Republic of Belarus or other legal act in accordance with the procedure defined by him, providing for the introduction of mandatory confirmation compliance in connection with the need to take measures of state regulation, or technical regulations of the Union (Customs Union). In this case, the declaration of conformity is replaced by mandatory certification.
Q2.
Is it possible on the territory of the Republic of Belarus, as documents confirming the conformity of products, to use extracts of declarations and certificates from the register of issued certificates of conformity and registered declarations of conformity, registered in the territory of the Russian Federation, and certified by the applicant in the established strand, for customs procedures and for the sale of goods in retail chains?
A2.
In accordance with the Treaty on the Eurasian Economic Union of May 29, 2014, certificates of conformity and declarations of compliance with the requirements of the technical regulations of the Eurasian Economic Union (Customs Union) issued in accordance with the Decision of the EEC Board of December 25, 2012 No. 293 (as amended by the Decision of the EEC Board of November 15, 2016 No. 154) (for products, falling under the technical regulations of the Eurasian Economic Union (Customs Union)).
The current documents on conformity assessment of products within the framework of the Eurasian Economic Union are the originals of certificates of conformity, declarations of conformity with the requirements of the technical regulations of the Eurasian Economic Union, or their copies made in accordance with the established requirements (paragraphs 9 (certificates) and 8 (declarations of conformity) of the above decision (copies of issued certificates are made by the applicant, copies of the registered declaration are made by the person who accepted this declaration).
National certificates of conformity, declarations of conformity of the Russian Federation do not have the right of direct circulation in the territory of the Republic of Belarus.
Submission of extracts from the register of issued certificates of conformity and registered declarations of conformity is not the basis for the legality of their use in the sale of products.
Q3.
Please clarify in what order, by whom and in what cases the validity of declarations of conformity in the Republic of Belarus is suspended or terminated?
A3.
The provisions providing for the validity of declarations of conformity (the effect of registration of declarations of conformity) in time, the effect of persons accepting declarations of conformity, bodies for registration of declarations of conformity and state bodies (officials) in relation to registered declarations of conformity are defined by Article 31 of the Law of the Republic of Belarus dated 24.10.2016 No. 437-Z "On Conformity Assessment and Accreditation of Conformity Assessment Bodies".
Within the framework of the Eurasian Economic Union, the Procedure for registration, suspension, renewal and termination of declarations of conformity of products with the requirements of the technical regulations of the Eurasian Economic Union is determined by the Decision of the Board of the Eurasian Economic Commission dated 20.03.2018 No. 41.
Q4.
Is a digital desktop clock with a battery-operated display subject to certification/declaration?
A4.
Table clocks on batteries with a digital display are subject to confirmation of compliance with the requirements of the technical regulations of the Customs Union "Electromagnetic compatibility of technical means" (TR CU 020/2011), the technical regulations of the Eurasian Economic Union "On limiting the use of hazardous substances in electrical engineering and radio electronics products" (TR EAEU 037/2016) in the form of a declaration of conformity. In the case of built-in telecommunication modules, you will need confirmation of compliance with the technical regulations of the Republic of Belarus "Means of communication. Safety" (TR 024BY).
Q 5.
Is complete electrical panel equipment up to 380V subject to mandatory certification?
A5.
Complete switchboard equipment with a nominal voltage of up to 380 V falls under the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011), "Electromagnetic compatibility of technical means" (TR CU 020/2011) (in the presence of active elements in relation to electromagnetic compatibility). It is subject to confirmation of compliance with TR CU 004/2011 in the form of certification and TR CU 020/2011 - declaration of conformity.
Q 6.
If the certificate of conformity of the CU has expired, is it possible to sell products that were imported into the territory of Belarus during the validity of the certificate?
A6.
According to paragraph 10 of Article 27 of the Law No. 437-Z "On Conformity Assessment and Accreditation of Conformity Assessment Bodies", products produced during the period of validity of the certificate of conformity issued to it may be in circulation after the cancellation (termination) of the relevant certificate of conformity within its service life, shelf life and (or) shelf life, except in cases, when the validity of the certificate of conformity was canceled (terminated) due to the non-compliance of the certified object of conformity assessment with technical requirements, the compliance with which was confirmed during certification, or canceled (terminated) in the cases and in the manner established by the President of the Republic of Belarus, persons (bodies) authorized by him. These norms are also established by paragraph 33 of the Rules.
Q 7.
The Declaration of Conformity of the Eurasian Economic Union was issued on the territory of the Russian Federation. Confirms that the products (HS code 9018199000 or 9018191000) meet the requirements of the technical regulations of the Customs Union TR CU 020/2011 "Electromagnetic compatibility of technical means". Can we use the above certificate issued in the Russian Federation for deliveries?
A7.
Certificates of compliance with the requirements of the technical regulations of the Customs Union (Eurasian Economic Union - EAEU), issued in any EAEU member state, including the Russian Federation, and entered into the Unified Register of Issued Certificates of Conformity and Registered Declarations of Conformity, are valid in the territory of the Republic of Belarus without re-registration.
The same applies to registered declarations of conformity.
Q 8.
Hello! Tell me, are TV and telephone sockets, as well as socket frames, subject to mandatory certification? Does this product fall under the 037 TR CU?
A8.
Currently, in the Republic of Belarus, products that are subject to the technical regulations of the Customs Union (Eurasian Economic Union - EAEU) and the Republic of Belarus, as well as included in the List of Objects of Mandatory Conformity Assessment of the National Conformity Assessment System of the Republic of Belarus, approved by the Resolution of the Council of Ministers of the Republic of Belarus on 21.10.2016 No. 849 (hereinafter - List).
Frames for sockets are not subject to mandatory confirmation of conformity in the Republic of Belarus.
TV and telephone sockets are subject to mandatory declaration of compliance with the requirements of the technical regulations of the Eurasian Economic Union "On Limiting the Use of Hazardous Substances in Electrical Engineering and Radioelectronics Products" (TR EAEU 037/2016). If the nominal voltage of this product is more than 50 V AC or 75 V DC, then it is also subject to mandatory certification according to the requirements of TR CU 004/2011 "On the safety of low-voltage equipment".
Q 9.
Is there a need to declare products according to the technical regulations certificate TR CU 010/2011, if there is a certificate TR CU 032/2011?
A9.
Currently, in the Republic of Belarus, products that fall under the technical regulations of the Customs Union (Eurasian Economic Union) or the Republic of Belarus, as well as included in the "List of objects of mandatory conformity assessment of the Republic of Belarus", approved by the Resolution of the Council of Ministers of the Republic of Belarus dated October 21, 2016 No. 849, are subject to mandatory confirmation of conformity.
In accordance with the section "Preface" (paragraph 3) of the technical regulations of the Customs Union "On the safety of equipment operating under excessive pressure" (TR CU 032/2013), if other technical regulations of the Customs Union are adopted in respect of the equipment, establishing requirements for it, then such equipment must also comply with the requirements of these technical regulations of the Customs Union.
Also, in accordance with the section "Preface" (paragraph 3) of the technical regulations of the Customs Union "On the safety of machinery and equipment" (TR CU 010/2011), if other technical regulations of the Customs Union, technical regulations of the Eurasian Economic Community (hereinafter referred to as the EAEU) establishing requirements for machines and (or) equipment are adopted in respect of machines and (or) equipment, then machines and (or) equipment must comply with the requirements of these technical regulations The Customs Union, the EAEU of which applies to them.
Thus, if the requirements of TR CU 010/2011 are also established in respect of products subject to TR CU 032/2013, then such products must comply with the requirements of both technical regulations.
Q 10.
Hello! Tell me, please, on what principle to compare products that are included in the Register of Hazardous and the documents that apply to it?
A10.
As part of the Internet portal "Quality.bel" there is an information system "Hazardous Products"(http://danger.gskp.by/), containing the Register of Dangerous Products Prohibited for Import and (or) Circulation in the Territory of the Republic of Belarus and the Register of Documents confirming the compliance of products with the requirements of the technical regulations of the Union, which have been terminated in the territory of the Republic of Belarus.
The register of dangerous products contains identification features of products (the name of the product and the manufacturer, images of the appearance and (or) labeling of products), which, according to the results of state supervision, is recognized as dangerous and prohibited for import and circulation in the territory of the Republic of Belarus, as well as information about the violated mandatory requirements, the number of the prescription, the date of introduction of the restrictive measure.
The register of documents that have been terminated contains information on the registration number of documents confirming the conformity of products that have been terminated in the territory of the Republic of Belarus, the body that issued (registered) the document, as well as information on the number of the prescription, the date of introduction of the restrictive measure.
When you press the computer mouse button on the document registration number information, the Document Register displays information on the name of the dangerous products included in the Register of Dangerous Products.
Q 11.
Good afternoon. I plan to import and sell charging stations for electric vehicles. For now, I plan to import from China. All charging stations are designed and manufactured in accordance with the requirements of international standards IEC61851. Is it necessary to additionally certify these products in Belarus for sale? If necessary, on compliance with what standards? Please specify the specific standard numbers.
A11.
Charging stations for electric vehicles are subject to confirmation of compliance with the requirements of the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011),
"Electromagnetic compatibility of technical means" (TR CU 020/2011). If charging stations can be used, among other things, by unqualified personnel (ordinary user), then the form of confirmation of conformity is certification. If the products are exclusively not for domestic use - declaration of conformity.
Currently, the List of international and regional (interstate) standards, and in their absence - national (state) standards, as a result of the application of which on a voluntary basis ensures compliance with the requirements of the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011) and the List of international and regional (interstate) standards, and in their absence - national (state) standards, containing the rules and methods of research (testing) and measurements, including the rules for sampling, necessary for the application and implementation of the requirements of the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011) and the implementation of conformity assessment of objects of technical regulation, the following standards are included:
– STB IEC 61851-1-2008 "Wired charging system for electric vehicles. Part 1. General requirements";
– GOST R IEC 61851-1-2013 "Wired charging system for electric vehicles. Part 1. General requirements";
– STB IEC 61851-21-2007 "Wired charging system for electric vehicles. Part 21. Requirements for electric vehicles in terms of connection to an AC or DC power supply".
To the List of international and regional (interstate) standards, and in their absence - national (state) standards, as a result of the application of which on a voluntary basis compliance with the requirements of the technical regulations of the Customs Union "Electromagnetic compatibility of technical means" (TR CU 020/2011) and the List of international and regional (interstate) standards, and in their absence - national (state) standards containing the following standards are included in the rules and methods of research (testing) and measurements, including the rules for sampling, necessary for the application and fulfillment of the requirements of the technical regulations of the Customs Union "Electromagnetic compatibility of technical means" (TR CU 020/2011) and the implementation of conformity assessment of objects of technical regulation:
– GOST 30804.6.1-2013 (IEC 61000-6-1:2005) "Compatibility of technical means electromagnetic. Resistance to electromagnetic interference of technical means used in residential, commercial and industrial areas with low energy consumption. Requirements and test methods";
– GOST 30804.6.3-2013 (IEC 61000-6-3:2006) "Compatibility of technical means electromagnetic. Electromagnetic interference from technical means used in residential, commercial and industrial areas with low energy consumption. Standards and test methods";
– STB IEC 61000-6-3-2012 "Electromagnetic compatibility. Part 6-3. Common standards. Norms of interference emission of equipment intended for installation in residential, commercial and industrial areas with low energy consumption";
– GOST R 52459.7-2009 (EN 301 489-7-2005) "Compatibility of technical means electromagnetic. Technical means of radio communication. Part 7. Specific requirements for mobile and portable radio equipment and auxiliary equipment of digital cellular communication systems (GSM and DCS)";
– GOST IEC 62041-2012 "Safety of transformers, reactors, power supplies and combined devices from them. Electromagnetic Compatibility (EMC) Requirements."
In addition, electric vehicle charging stations can be equipped with built-in communication facilities. In the case of the presence of built-in means (modules) of telecommunications, it will be necessary to confirm compliance with the technical regulations of the Republic of Belarus "Means of communication. Safety" (TR 024BY).
Q 12.
Good day! Is it necessary to indicate the number of the technical regulations of the Customs Union (TR TS 004, TR TS020, TRTS 037) in the product labeling (electrical products, imports). Is this a mandatory requirement for imported products?
A12.
Requirements for marking and operational documents are established in article 5 of the specified technical regulations of the Customs Union, according to which the mandatory requirement in terms of indicating the TR CU number is not established.
At the same time, in accordance with Article 8 of the specified TR CU, products are marked with a single sign of product circulation on the market of the Member States of the Customs Union if it meets the requirements of all technical regulations of the Customs Union (EAEU), which apply to it and provide for the application of this mark.
At the same time, in accordance with clause 1.1.1 of the resolution No. 64/30/81/47 of August 5, 2019, "On the procedure for confirming the availability of documents on the quality and safety of goods during their sale." For goods subject to mandatory certification, the presence of a certificate of conformity of the National System of Attestation of Conformity of the Republic of Belarus or the certificate of conformity provided for by the Treaty on the Eurasian Economic Union of May 29, 2014 (hereinafter - the Treaty on the Eurasian Economic Union), issued in a unified form (hereinafter - the certificate of conformity) , is confirmed in one of the following ways:
the original of the certificate of conformity;
- a copy of the certificate of conformity, made on forms with a certain degree of protection, certified by the certification body that issued the certificate; a photocopy of the certificate of conformity made from its original or a copy certified by the signature of the head of a legal entity (an authorized official) or an individual entrepreneur who are suppliers of goods;
- the presence on the product and (or) on its consumer packaging of the marking with the conformity mark of the National System of Conformity of the Republic of Belarus indicating the registration number of the certificate of conformity, the dates of registration and expiration (termination) of its validity (validity period), full name, location and address (addresses) of the place of business (if the addresses differ) of the certification body that issued the certificate of conformity;
- an indication in the accompanying documents confirming the purchase (receipt) of goods, and (or) technical passports, and (or) operating instructions, and (or) other accompanying documentation for a batch of products or attached to each unit of goods for each product name, registration number certificate of conformity, dates of registration and expiration (termination) of its validity (validity period), full name, location and address (addresses) of the place of business (if the addresses differ) of the certification body that issued the certificate of conformity, if this information is not indicated on the product or its consumer packaging.
Q 13.
Is it a violation to indicate in the certificates of conformity and declarations of conformity the names of manufacturers, their locations (addresses of legal entities), as well as the addresses of the places of implementation of activities for the manufacture of products and designation of products using modified letters of the Latin alphabet (letters of the Latin alphabet with the addition of diacritics) ?
A 13.
According to the clarifications of the Department of Technical Regulation and Accreditation of the Eurasian Economic Union (http://eec.eaeunion.org/section: Activity / Technical Regulation / Current Issues / Conformity Assessment), the declaration of conformity with the requirements of the technical regulation of the Eurasian Economic Union is drawn up according to uniform forms and rules, approved by the Decision of the Board of the Eurasian Economic Commission (hereinafter referred to as the Commission) dated 25.12.2012 No. 293 (as amended by the Decision of the Board of the Commission No. 154 dated 15.11.2016, which entered into force on 22.12.2016) (hereinafter respectively - the declaration of conformity, Decision No. 293) ...
The third paragraph of clause 3 of the Rules for drawing up a declaration of conformity provides that, if necessary, the name of the manufacturer, its location (address of the legal entity), as well as the address (addresses) of the place of implementation of activities for the manufacture of products (except for the name of the state) and designation of products (type, brand, model, article, etc.) can be indicated using letters of the Latin alphabet.
At the same time, Decision No. 293 does not prohibit the use of modified letters of the Latin alphabet (letters of the Latin alphabet with the addition of diacritics) in the declaration of conformity when specifying the name of the manufacturer, its location (address of the legal entity), as well as the address (addresses) of the place of business for the manufacture of products (except for the name of the state) and the designation of products (type, brand, model, article, etc.).
At the same time, we would like to draw your attention to the fact that the information contained in the declarations of conformity with the use of modified letters of the Latin alphabet in order to provide the most accurate presentation of information about the main identification features of products in the declaration of conformity must be clear, easy to read, reliable and not mislead consumers ( purchasers)
Q 14.
What certificates of conformity are required by the legislation of the Republic of Belarus for a mobile phone (smartphone) of the GSM (2G), UMTS (3G), LTE (4G) standards?
A 14.
Mobile phones (without power supply) of GSM (2G), UMTS (3G), LTE (4G) standards,
are subject to mandatory confirmation of compliance with the requirements of the technical regulations of the Customs Union "Electromagnetic compatibility of technical equipment" (TR CU 020/2011) and "On the restriction of the use of hazardous substances in electrical and electronic products" (TR EAEU 037/2016) in the form of a declaration of conformity.
We also inform you that the Technical Regulations of the Republic of Belarus “Telecommunications Means. Security "(TR 2018/024 / BY), approved by the Resolution of the Council of Ministers of the Republic of Belarus No. 469 dated 20.06.2018, which applies to broadband access equipment, including radio modules that are part of other equipment and to terminal subscriber devices of cellular mobile systems. telecommunications, including radio modules that are part of other equipment (paragraphs 6.9 of Appendix No. 2 TR 2018/024 / BY).
Consequently, the above products are subject to technical regulation of the technical regulations of the Republic of Belarus TR 2018/024 / BY and are subject to mandatory confirmation of conformity in the form of a declaration of conformity.
In addition, external power supplies (chargers) for mobile phones are subject to confirmation of compliance in the form of certification of compliance with the technical regulations of the customs union TR CU 004/2011, TR CU 020/2011, as well as the standard of the Republic of Belarus “External power sources. Energy efficiency. Requirements for electricity consumption in idle mode and average effective efficiency "STB 2463-2016.
Q.15.
good afternoon. Do I need to receive a new declaration of conformity for products if the name of the manufacturer has changed (only the name, the address remains the same)?
A 15.
The declaration is subject to registration on the basis of the application of the person receiving the declaration, with the attachment of documents (information) to the body for registration of declarations. The application form for registration of the declaration is established by the rules of conformity confirmation.
The declaration comes into force from the date of its registration (assignment of a registration number and making a corresponding entry) by the body for registration of declarations in the register of the National System of Attestation of Conformity of the Republic of Belarus or national parts of unified registers of documents on conformity assessment. The registration of the declaration is valid for the period specified in the corresponding registered declaration.
The person accepting the declaration is responsible for the legality of the declaration, including whether he has the right to accept it, the completeness and accuracy of the information it contains. The declaration of conformity must indicate the full name of the manufacturer, including the location, including the actual address.
When the information about the manufacturer of the product is changed, the reliability and completeness of the information specified in the declaration of conformity is violated. The applicant independently decides on the need to adopt a new declaration of conformity in the event of a change in the information specified in it.
The registration of a declaration may be terminated by the declaration registration authority that registered the corresponding declaration, at the initiative of the person receiving the declaration.
Q 16.
Are used computers imported from the European Union to the EAC subject to confirmation of conformity if they are to be used for their own use?
A 16.
Having considered your electronic request, within the limits of our competence, we inform you that the products:
- computers,
is the subject of technical regulation of the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011), "Electromagnetic compatibility of technical equipment" (TR CU 020/2011).
Technical regulations TR CU 004/2011 and TR CU 020/2011 do not contain exceptions for products imported for their own use, as well as used products.
In accordance with Article 53 of Section X of the Treaty on the Eurasian Economic Union (EAEU) dated May 29, 2014, products for which the Union technical regulations (Union technical regulations) have come into force are released into circulation on the territory of the Union, provided that they have passed the necessary conformity assessment procedures established by the technical regulations of the Union (technical regulations of the Union).
In accordance with Appendix No. 9 to the Treaty on the Eurasian Economic Union (Protocol on Technical Regulation within the Eurasian Economic Union), the term “release of products into circulation” is defined as “delivery or import of products (including dispatch from the manufacturer's warehouse or shipment without warehousing) for the purpose of distribution on the territory of the Union in the course of commercial activities on a gratuitous or reimbursable basis. "
When importing products for personal consumption into the territory of the Eurasian Economic Union, one should be guided by the "Regulations on the procedure for importing products (goods) into the customs territory of the Customs Union, for which mandatory requirements are established within the Customs Union", approved by the Decision of the Board of the Eurasian Economic Commission dated December 25. 2012 No. 294, according to which it is not required to provide customs authorities with documents certifying the compliance of products (goods) with mandatory requirements, or information about such documents for products imported (imported) in single copies (quantities) provided for by one foreign trade agreement, exclusively for their own use declarant (including for research or representative purposes as souvenirs or promotional materials).
The condition for the use of the above provision is the availability of relevant supporting documents.
Based on the above, we believe that products that are subject to technical regulation of the technical regulations of the Customs Union, imported for the purposes of further use by the applicant, must have conformity confirmation documents.
Q 17.
Are e-cigarettes imported from China to EAC subject to mandatory certification?
A 17.
In accordance with the requirements of the technical regulations of the Customs Union "Electromagnetic compatibility of technical equipment" (TR CU 020/2011), products - an electronic steam generator without a power supply (electronic disposable cigarette) are subject to the specified technical regulations of the Customs Union and are subject to mandatory confirmation of conformity in the form of a declaration of conformity.
Please note that the power supply, if it is included in the set of the electronic steam generator, is subject to technical regulation of the technical regulations of the Customs Union "On the safety of low-voltage equipment" (TR CU 004/2011) and "Electromagnetic compatibility of technical equipment" (TR CU 020/2011 )
In addition, external power supplies (power supplies, chargers are subject to confirmation of compliance in the form of certification of compliance with the standard of the Republic of Belarus "External power supplies. Energy efficiency. Requirements for electricity consumption in idle mode and average effective efficiency" STB 2463-2016.
Q 18.
Whether smart watches and fitness bracelets imported into EAC need to be certified.
A 18.
The technical regulations of the Customs Union "Electromagnetic compatibility of technical means" (TR CU 020/2011) apply to products:
- smart children's watches, subject to the presence of active electronic circuits in the design, therefore, it is an object of technical regulation of the technical regulations of the Customs Union and is subject to mandatory confirmation of conformity in the form of a declaration of conformity.
We would also like to draw your attention to the fact that provided that smart children's watches, fitness bracelets have SRD, Wi-Fi, Bluetooth, GSM radio modules, products are subject to mandatory confirmation of conformity in the form of a declaration of conformity with the requirements of the Technical Regulations of the Republic of Belarus “Telecommunications. Security "(TR 2018/024 / BY).
We also inform you that on March 1, 2018, the technical regulation of the Eurasian Economic Union "On the limitation of the use of hazardous substances in electrical and radioelectronic products" (TR EAEU 037/2016) entered into force, which applies to electrical and electronic watches (list p) of clause 1 1 of the EAEU TR 037/2016), therefore, we believe that the products you are interested in - smart children's watches - are subject to technical regulation of the specified technical regulations and are subject to mandatory confirmation of conformity in the form of a declaration of conformity.
Q.19.
Please clarify the following question. The manufacturer has changed its name. The location and address of the place of business remains the same. Is it necessary in this case to re-pass the conformity confirmation procedure in the form of a conformity declaration?
A 19.
The declaration of conformity with the requirements of the technical regulations of the Eurasian Economic Union is drawn up in a unified form and rules approved by the Decision of the Commission Board dated December 25, 2012 No. 293 (as amended by the Commission Board Decision No. 154 dated November 15, 2016) (hereinafter respectively - the declaration, the Union , Rules for filling out the declaration).
According to subparagraph "c" of paragraph 5 of Section II of the Rules for filling out the declaration in field 5 of the declaration, the full name of the manufacturer, its location (address of the legal entity) and the address (addresses) of the place of implementation of activities for the manufacture of products (if the addresses differ) are indicated - for a legal a person and its branches that manufacture products, or surname, name and patronymic (if any), place of residence and address (addresses) of the place of implementation of activities for the manufacture of products (if the addresses differ) - for an individual registered as an individual entrepreneur ...
The rules for drawing up the declaration do not allow any correction of the text of the declaration, the introduction of information not provided for by the Rules for drawing up the declaration, as well as the abbreviation of words (except for generally accepted designations and abbreviations).
It should be noted that in accordance with clause 11 of the Regulation on the registration of declarations of conformity of products with the requirements of the technical regulations of the Customs Union, approved by the Decision of the Board of the Commission No. 76 dated April 9, 2013 (hereinafter referred to as the Regulation), amendments to the registered declaration are not allowed. If it is necessary to make changes, the applicant accepts a new declaration and carries out its registration in the manner prescribed by the Regulations.
Thus, if any information contained in the declaration is changed, including the change in the name of the manufacturer, the declaration requires renewal.
Q.20.
Can a foreign manufacturer act as an applicant for product certification in the EAEU?
A 20.
In accordance with clause 5 of the Protocol on technical regulation within the framework of the Eurasian Economic Union (Appendix No. 9 to the Treaty on the Eurasian Economic Union of May 29, 2014) (hereinafter, respectively, the Protocol, the Treaty), when assessing conformity, the applicant may be registered in the territory of a member state Union, in accordance with its legislation, a legal entity or an individual as an individual entrepreneur who is a manufacturer or seller or a person authorized by the manufacturer.
A similar norm is established by paragraph 2 of the rules for issuing a certificate of conformity, approved by the Decision of the Board of the Commission dated December 25, 2012 No. 293
(as amended by the Decision of the Board of the Commission dated November 15, 2016 No. 154, which entered into force on December 22, 2016).
Issues related to customs clearance of products when importing goods to the market of the Eurasian Economic Union
Q 1.
Is the certificate of conformity for products checked directly at the customs border?
A 1.
No. Documents are presented when submitting a customs declaration for customs clearance.
Q 2.
Is it possible to submit a certificate of conformity of another country for customs clearance?
A 2.
In certain cases. On the territory of Belarus, during customs clearance, you can use the documents of conformity of the EAEU countries (Russia, Kazakhstan, Kyrgyzstan, Armenia) containing "TS" or "EAEU" in their number. Conformity confirmation documents from other countries are not accepted by the Belarusian customs authorities.
Q 3.
What attributes must a conformity confirmation document contain in order to be accepted by the customs authorities?
A 3.
The document must be certified by the seal of the applicant and / or the authority that issued it. The submitted copy must also be certified by the applicant indicated in the certificate / declaration.
Q 4.
Is it possible to carry out customs clearance of goods subject to certification / declaration of conformity without the appropriate documents?
A 4.
The import of goods subject to the obligatory conformity confirmation procedure without the necessary certificates / declarations can be carried out only in single copies for their own needs (not for sale) or in order to confirm conformity.
Q 5.
What to do if the cargo arrived at the customs clearance point, but there are no necessary documents on compliance?
A 5.
In this case, the cargo will remain in the temporary storage warehouse until the relevant documents are received for it or it is exported under the re-export procedure.
Q 6.
Is it allowed to mark products that are the subject of technical regulation of the technical regulations of the Eurasian Economic Union (technical regulations of the Eurasian Economic Union) with a single mark of product circulation on the Eurasian Economic Union market after the import of these products to the customs territory of the Eurasian Economic Union?
A 6.
In accordance with the provisions of the Treaty on the Eurasian Economic Union dated May 29, 2014 (hereinafter referred to as the Treaty, the Union) in the field of technical regulation, the technical regulations of the Union establish the requirements for the objects of technical regulation that are binding on the Union's territory.
According to clauses 3 and 6 of the Protocol on technical regulation within the framework of the Eurasian Economic Union (Appendix No. 9 to the Agreement) (hereinafter referred to as the Protocol), the technical regulations of the Union may establish, inter alia, requirements for product labeling, while product labeling with a single product circulation mark on Union market (hereinafter referred to as the unified circulation mark) is a mandatory requirement for products for which the Union's technical regulations have been adopted.
In accordance with paragraph 2 of Article 53 of the Treaty, products for which the technical regulations of the Union (technical regulations of the Union) have come into force are released into circulation in the territory of the Union, provided that they have passed the necessary conformity assessment procedures established by the technical regulations of the Union (technical regulations of the Union ).
Release of products into circulation in accordance with paragraph 2 of the Protocol is defined as the supply or import of products (including dispatch from the manufacturer's warehouse or shipment without storage) for the purpose of distribution in the territory of the Union in the course of commercial activities on a gratuitous or reimbursable basis.
It should be noted that, in accordance with clause 5 of the Protocol, the conformity assessment of the products released into circulation with the requirements of the technical regulations of the Union is carried out before their release into circulation.
According to clause 2 of the Procedure for the application of a single mark of product circulation on the market of the Eurasian Economic Union, approved by the Decision of the Customs Union Commission dated July 15, 2011 No. 711 (as amended by the Decision of the Commission Council dated March 17, 2016 No. 22), marking with a single circulation mark is also carried out before the release of products into circulation on the Union market.
The procedure for importing products subject to mandatory conformity assessment, including products subject to conformity assessment with the requirements of technical regulations of the Union, is established by the Regulation on the procedure for importing products (goods) into the customs territory of the Customs Union, in respect of which mandatory requirements are established within the framework of the Customs Union (hereinafter - Regulations on the import procedure), approved by the Decision of the Board of the Commission dated December 25, 2012 No. 294.
The Regulation on the Procedure for Importation establishes that, in relation to the products (goods) provided for in paragraph 2 of the Regulation on the Procedure for Importation, when declaring it simultaneously with the customs declaration, the customs authorities are required to submit documents certifying the compliance of such products (goods) with mandatory requirements, or information about such documents.
The regulation on the import procedure also provides for a list of documents certifying the compliance of products (goods) with mandatory requirements, and types of customs procedures (clause 4 of the Regulation on the import procedure), when placed under which such documents (information about such documents) are required or not required.
Taking into account the foregoing, products that are the subject of technical regulation of the technical regulations of the Union (technical regulations of the Union), meeting all the requirements for them, established by the technical regulations of the Union (technical regulations of the Union), and having passed the conformity assessment procedures provided for by the technical regulations of the Union (technical regulations of the Union), when placed under the customs procedures provided for in clause 4 of the Regulation on the procedure for importation, must be marked with a single sign of circulation.
Questions related to the Technical Regulations of the Republic of Belarus
“Telecommunications Means. Safety".
Questions relating to article 1. "Scope"
Q 1.
In accordance with the scope of application of the technical regulations, built-in means of communication (Wi-Fi-communication modules,fax, Bluetooth, etc.) or terminal devices in which these modules are built-in (TV, washing machine, laptop, etc.) are subject to confirmation of compliance?
A 1.
In accordance with the scope of application of the technical regulations, terminal devices in terms of embedded communication modules (TV, washing machine, laptop, etc.) are subject to confirmation of compliance.
Telecommunication facilities imported by legal entities and individual entrepreneurs as components, materials for use in their own production (telecommunication modules) if they have documents on conformity assessment of the National Conformity Assessment System of the Republic of Belarus for finished products produced using these components, materials, do not require confirmation of conformity.
In the event that telecommunication modules are placed on the market of the Republic of Belarus for sale on the market of the Republic of Belarus separately from the terminal equipment, in this case confirmation of compliance of the telecommunication module itself is required.
Q 2.
The technical regulations do not apply to the receivers of television and radio broadcasting, but whether the technical regulations apply to the telecommunication facilities built into the receivers of television and radio broadcasting (Wi-Fi. Bluetooth, etc.)?
A 2.
The technical regulations do not apply to the receivers of television and radio broadcasting only if these receivers do not have Wi-Fi transmitting modules. Bluetooth, etc., that is, in the case when the receivers of television and radio broadcasting work only to receive a signal.
If Wi-Fi telecommunications are built into the receivers of television and radio broadcasting. Bluetooth, etc., such receivers of television and radio broadcasting are subject to assessment of compliance with the requirements of technical regulations.
Conformity assessment shall be carried out in respect of communication facilities built into the final equipment (communication modules), while the functioning of integrated communication facilities in the final equipment (televisions, radios, laptops, wireless keyboards, mice, etc., with respect to embedded communication modules) is evaluated.
Q 3.
Does the technical regulation apply to satellite navigation equipment?
A 3.
The technical regulations do not apply to satellite navigation equipment in accordance with paragraph 2 of Article 1 of TR 2018/024 / BY, satellite navigation equipment works only to receive a signal from satellites. Bluetooth, etc.) - satellite navigation equipment - requires confirmation of conformity.
Q 4.
What is the equipment designed for the amateur radio service?
A 4.
Amateur radio service - a radio service for the purposes of self-improvement, mutual radio communication and technical research carried out by citizens who have permission to do so and are engaged in radio engineering solely out of personal interest, without obtaining material benefits (a technical hobby consisting in conducting radio communications between non-professional operators in the radio frequency ranges allocated for this purpose).
The main distinguishing features of the equipment of the amateur radio service are:
- The equipment of the amateur radio service is stationary with reference to the address and geographical coordinates;
- For the acquisition and operation of the equipment of the amateur radio service, a permit is required for the manufacture, acquisition, import from abroad and operation of radio transmitting stations;
- An amateur radio operator goes on the radio air only on the basis of a license (permit) issued to him using the call sign assigned to him.
The rules for issuing permits for the manufacture (acquisition) and operation of amateur transceiver radio stations, the rules of amateur radio communication are established in the regulations - "Amateur and Amateur Satellite Radio Communication Services of the Republic of Belarus", approved by Order No. 76 of the Ministry of Communications and Informatization of the Republic of Belarus on July 5, 1996.
Q 5.
Do I need proof of conformity for automotive radars operating in the 77 GHz frequency band?
A 5.Requirements of the Technical Regulations of the Republic of Belarus "Telecommunications facilities. Safety" applies to automotive radars operating in the frequency range from 25 MHz to 40 GHz (subparagraph 8 of Annex 2). Requirements of the Technical Regulations of the Republic of Belarus "Telecommunications facilities. Safety" does not apply to embedded radio modules operating in the frequency ranges up to 25 MHz and more than 40 GHz., correspondingly, automotive radars in the 77 GHz frequency band do not require confirmation of compliance.
Questions relating to article 3. "Technical requirements"
Questions relating to article 5. "Schemes for confirming the compliance of telecommunication facilities with technical requirements"
Table 1. Forms of conformity assessment (serial issue).
Q 16.
What documents should the applicant provide for certification/declaration?
A 16.
To the application for certification / declaration of products, the applicant attaches the documents specified in Table 2.
Table 2. Attached documents.
Please note that radio-electronic means of communication must work in dedicated radio frequency bands with regulated parameters in accordance with the decisions of the State Commission on Radio Frequencies under the Security Council of the Republic of Belarus
Q 17.
Can the compliance of the device in the model name of which there are asterisks (*) in place of which there may be a letter or numeric designation of the changed parameters of the device?
A 17.
It is not recommended to confirm the compliance of devices in the name of models with asterisks (*). The exceptions are models where only the part of the name related to marketing is indicated by asterisks, for example, the country of delivery, color, etc., while the technical documentation (paragraph 1 of Table 2, answer 12) should contain a decoding of the designations for each asterisk (*).
Questions related to testing, choosing a representative from a group of models and providing samples for testing
Q 18.
How is the selection of a typical representative from a product group carried out to confirm compliance and test telecommunication facilities?
A 18.
The choice of a typical representative from a group of products of the same type (a group of end products of the same name, purpose and application, for example, televisions or refrigerators, or printing devices), to confirm compliance, is carried out on the basis of:
- identical purpose of devices from one manufacturer (TV, refrigerator, printer or MFP, etc.);
- identical functionality of devices (LED, OLED, PLASMA, LCD, inkjet printer or MFP, laser printer or laser MFP, etc.);
- the presence of the maximum set of functions of the end device (for example, for MFP - printer, scanner, copier, monitor, etc.);
- availability of identical names of built-in telecommunication modules;
- an identical version of the pre-installed software for identical communication modules installed in a group of devices (products) of the same type.
Q 19.
Who selects a typical representative from a product group (certification body or manufacturer)?
A 19.
The choice of a typical representative from a product group is carried out by the manufacturer of the product and sends to the certification body a declaration justifying the choice of a typical representative from the product group, to confirm compliance and conduct tests. The declaration must contain:
- criteria and justifications for choosing a product group;
- criteria and justifications for choosing a typical representative from a product group.
Together with the declaration on the justification for the choice of a typical representative from the product group, technical documentation for each model from the product group must follow (paragraph 1 of Table 2, answer 12).
The selection of samples for testing is carried out by representatives of the certification bodies of the Republic of Belarus (representatives of the accredited laboratory of the certification body).
Q 20.
In what cases is it required to test products in accredited laboratories of the Republic of Belarus?
A 20.
Mandatory product testing in accredited laboratories of the Republic of Belarus is required:
- when certifying telecommunication devices (Appendix 1 of the technical regulation) according to schemes - 1s, 3s, 4s conformity confirmation system of the Republic of Belarus);
- when declaring telecommunication devices (Appendix 2 of the technical regulation) according to schemes - 3d and 4d. (when declaring devices according to schemes 1d and 2d only for wired telecommunication devices specified in paragraphs 1-5 of Appendix 2 and according to scheme 6d (provided that the manufacturer has a quality management system certified in the National Conformity Attestation System of the Republic of Belarus), test reports may be accepted in the manufacturer's own accredited testing laboratory).
Q 21.
To test a product sample with built-in communication modules, do you need to submit for testing the final products in which communication modules are built-in (for example, a laptop) or are the communication modules themselves enough without the product?
A 21.
To test a sample of products with built-in communication modules, it is necessary to provide a sample (samples) of the final equipment with built-in communication modules (for example, a laptop).
Q 22.
To test a large-sized sample of products with built-in communication modules, is it necessary to transfer for testing the final products in which the communication modules are built (for example, a tractor or a car) or are only communication modules enough without a product in which these communication modules are built?
A 22.
To test a large-sized sample of products with built-in communication modules, it is necessary to provide a sample (samples) of modular blocks of the final product in which communication modules are built-in, with a device for connecting to the power supply and with test auxiliary equipment that provides connection and control of the module, as well as software software for activation and control of the communication module. If it is impossible to provide a sample (samples) of modular units (electronic units), it is required to provide communication modules with a device for connecting to the power supply and with test auxiliary equipment that provides connection and control of the module, as well as software for activation and control of the communication module. In the case of tests of the built-in communication modules from the manufacturer / manufacturer, an additional declaration of conformity of products with the built-in communication module to the technical requirements of TR 2018/024 / BY (article 3) will be required. The declaration must reflect and justify technical solutions for the placement and operation of the communication module in the final product, taking into account the requirements of paragraphs 2 - 4 of Article 3 of the technical regulation.
Q 23
If more than one communication module with identical technical characteristics (for example, 802.11abgn / ac + Bluetooth) can be used in the final product (for example, a laptop or TV) and the product may be supplied to the Republic of Belarus with different communication modules, what equipment is required to provide tests?
A 23
In this case, everything depends on the design of the final product and the communication module.
If the communication module and the final product are designed in such a way that the module can be replaced in the laboratory with another module with identical technical characteristics without the need to interfere with the microcircuits of the final product (for example, the module can be inserted into an existing interface, connector) and the case of the final product provides for the possibility of For this operation (a collapsible case or a case with a window for replacing a module, or an external connector for connecting a module) - in this case, for testing, it is sufficient to provide one final product (for example, a laptop) and all variants of communication modules with identical technical characteristics and interfaces. The final product must be tested with all built-in communication modules with which it can be placed on the market of the Republic of Belarus. If the case of the final product does not provide for the possibility of replacing the communication module in the laboratory, or for testing it is necessary to interfere with the microcircuits of the final product (soldering, etc.) - in this case, for testing, it is required to provide all versions of the final products with built-in communication modules. In this case, the samples should be equipped with SMA connectors connected to the wireless communication modules for connecting an external antennAnswer For GSM communication modules, slots for installing a test SIM card must be provided (devices with electronic E-SIM cards are not tested). In any case, all possible combinations of communication modules in the final product must be tested.
Q 24.
Are there general requirements for samples of radio-electronic equipment for testing?
A 24.
As a rule, the requirements for samples for testing radio-electronic equipment may differ depending on the purpose of the equipment, the communication technologies used, the operating conditions, therefore, we recommend in each case to contact the representatives of the accredited testing laboratories of the Republic of Belarus to clarify the requirements.
General requirements:
For testing, it is required to provide the final product with built-in communication modules (for example, a laptop), in the case of large overall dimensions of the final product, modular blocks of the final product (electronic part) are provided for testing, in the case of large overall dimensions of the modular units of the final product (electronic parts) for testing, a decision can be made to provide built-in radio communication modules with test auxiliary equipment that provides connection and control of the module, as well as software that allows you to activate and control the communication module. On samples, without fail, technical markings must be applied to enable identification of the model, serial number, trademark of the manufacturer of the tested sample and model, serial number, trademark of the manufacturer of the built-in communication module.
In general, samples should be supplied with:
- all accessories necessary for the device to operate in standard mode in a terminal product with the ability to connect them, antennas (antenna units, intelligent antenna systems), power cables (including antenna power cables), power supplies (if necessary), wire communication cables for connections of external devices, antenna cables, other electronic equipment connected to the device (in agreement with the testing laboratory), in this case, a technical manual for connecting and putting the device into operating modes should be attached (it is desirable that the manufacturer of the device has a technical support service in the Republic of Belarus).
- the minimum configuration of the wireless communication module under test must include a connector (s) connected to the SMA module for connecting an external antenna, indicating the characteristics of an external antenna, while a technical manual for connecting and putting the device into operating modes must be attached (it is desirable that the manufacturer of the device has technical support service in the Republic of Belarus)
The combination of radio modules in a final product (integration of several radio modules into one product) requires a careful assessment of compliance with the basic requirements of the technical regulation in relation to electromagnetic compatibility. For example, a signal from a radio transmitter can create harmonic interference in other parts of the product's microcircuits and generate intermodulation products (as a result, new spectrum components appear that noise the received signal) with other sources of radio waves. These can be both local generators of radio receivers and radio frequency generators of radio transmitters.
Therefore, in addition to testing according to radio communication standards, the end product must be tested according to EMC standards (parts of GOST ETSI EN 301 489, regulating the requirements for specific radio electronic communications).
Q 25.
Are additional technical documents required for testing, in an attachment to a sample of electronic communications equipment?
A 25.
For testing, the manufacturer must provide information on the type of equipment to which it belongs (stand-alone, combined or MR equipment). For a preliminary assessment of the equipment, it is necessary to submit the documents specified in paragraph 1 of Table 2, question 12 and the technical manual for connecting and putting the device into operating modes. Also, for 5 GHz wireless access equipment (WAS), including RLAN equipment, it is necessary to provide an application form for testing in accordance with Appendix G of the ETSI EN 301 893 V2.1.1 standard (2017-05) or the information requirements for which are imposed by subparagraph 5.4.1 of the ETSI EN standard 301 893 V2.1.1 (2017-05), for wireless access equipment 2,400 MHz - 2,483.5 MHz, an application form for testing in accordance with Appendix E of ETSI EN 300 328 V2.1.1 (2016-11) or information requirements for which are presented by subparagraph 5.4.1 of the ETSI EN 300 328 V2.1.1 (2016-11) standard.
Issues related to the requirements for attestation of conformity in the energy efficiency of household appliances in Belarus
Q 1.
The degree of identity between the standards of the Republic of Belarus and the regulations of the European Union?
A 1.
The standards of the Republic of Belarus in the field of energy efficiency of household and office equipment were developed on the basis of the relevant European Commission Regulations concerning the rules for the application of Directive 2010/30 / EU of the European Parliament and of the Council. The order of presentation of requirements in the standards and Regulations is different, the requirements and scope of the standards correspond to the text of the European Regulations at the time of adoption of the standards. The content of the energy efficiency label meets European requirements, the label design has been changed (the label is issued in Russian and Belarusian).
The standards STB 2248-2012 and STB 2269-2012 were developed and adopted in 2012, therefore, these standards do not take into account changes in European regulations.
Q 2.
The procedure for confirming compliance with the standards of the Republic of Belarus in the field of energy efficiency?
A 2.
Confirmation of conformity in the field of energy efficiency is carried out in the form of certification, declaration of conformity is provided only for asynchronous electric motors STB 2332.
Having chosen an accredited certification body, it is necessary to send an application of the established form to it. After checking the application for correctness of filling, the certification body sends its written response.
Documents attached to the application for certification purposes:
- manual;
- a sample label of the energy efficiency of the product;
- a sample of the technical sheet of the product;
- technical documentation (if necessary);
We recommend that you provide technical documentation to the product certification body when applying for certification for the completeness of the project documents in case the certificates are checked by the supervisory authorities.
- production inspection report (Form CIG 023) or production inspection report; the document is valid for 1 year from the date of the inspection;
- reports of tests carried out in an accredited laboratory (if any) (approval is valid until 01.09.2018);
From 01.09.2018, testing of a product sample in accredited laboratories of the Republic of Belarus is required);
- in the absence of test reports, a sample of products is required for testing in an accredited laboratory of the Republic of Belarus;
- certificates of conformity of products to the requirements of the EAC technical regulations.
If there are no problems with the primary forms, the certification body sends the applicant a positive decision, which indicates the procedure for certification of products in the Republic of Belarus, information about the testing laboratory, the procedure for sampling for research, payment terms and a list of regulatory documents for compliance with which the verification will be carried out.
Q 3.
General requirements for the documentation provided to the certification body?
A 3.
The documentation must be provided in Russian or Russian and Belarusian and contain the information required by the standards in the manner prescribed by the standards.
In Russian or Belarusian:
- manual;
- a sample label of the energy efficiency of the product;
- a sample of the technical sheet of the product;
- test reports (can be provided in English by agreement with the certification body).
Requirements for the content of technical sheets, the content and design of energy efficiency labels are established in the standards for specific types of products.
Requirements for the design and content of test reports are established in the test standards.
Copies of the documents attached to the application must be certified by the signature and seal of the applicant. Documents in a foreign language (test reports) must be accompanied by a translation into Belarusian or Russian (if necessary).
Q 4.
Need a label for energy efficiency of products and their presence on packaging?
A 4.
For devices that are not displayed at a retail outlet (for example, stored in a warehouse), it is allowed not to apply the label directly to the sample, but to attach it to the accompanying documentation (for example, to the operating manual), while the label must be made in color.
In accordance with the requirements of the standard for specific products. Provides for the application of an energy efficiency label to product samples displayed for sale in retail outlets. The label is affixed to the front or top of the appliance (with the expectation that the customer should see it from in front of the appliance), or in the immediate vicinity of the appliance so that it is clearly visible and recognizable as a label for the model. If the model of the device is shown in the sales area only in packaging (wholesale stores), in this case it is permissible to apply the label to the part of the packaging visible to the buyer.
Q 5.
Criteria for combining equipment models into one certificate?
A 5.
The criterion for defining models of equipment in one certificate will be the definition of an equivalent model for testing and confirmation of conformity. The definition of an equivalent model differs depending on the type of home and office equipment. Definitions will be added to the text of all standards coming into force requiring conformity assessment for energy performance.
Q 6.
Is it acceptable that the declared value of energy consumption in the test report for certification was less than the value obtained during the verification tests, but not more than 10%?
For reference, in accordance with the verification procedure for the purpose of market surveillance, it is permissible that the measured value on the specimen is 10% higher than the nominal value.
A 6.
Acceptable within the control tolerances established in the section of the standard - verification procedure, for a specific type of equipment, taking into account that the measured values of energy consumption do not affect the value of the energy efficiency index and correspond to the declared one (indicated on the label, in the technical sheet, test report) energy efficiency class.
Q 7.
Is it acceptable to include noise test results obtained in another manufacturer's laboratory in the energy performance test report? What is the procedure for recognizing these results?
A 7.
Acceptable. The indicator of the corrected sound power level is not regulated in most standards.
The manufacturer declares it on the basis of the tests performed.
This parameter is monitored by regulatory authorities when verifying compliance with the requirements for energy efficiency.
Q 8.
What is the forecast regarding the adoption of the TR CU on energy efficiency?
Will national energy efficiency requirements be in effect during the transition period of the TR CU?
What is the procedure for issuing permits for the TR CU based on the national certificate of the Republic of Belarus?
A 8.
There is no decision on the adoption of the EAEU technical regulation "On Energy Efficiency Requirements for Energy-consuming devices" yet. If it is adopted in 2018, the deadline for the introduction of requirements is 2021, plus a transitional period of 18 months. Until then, the requirements of the national standards of the Republic of Belarus for energy efficiency will be in effect on the territory of the Republic of Belarus. If there is a valid certificate of the Republic of Belarus, at the time of entry into force of the requirements of the technical regulations of the EAEU, the certificates will be reissued in accordance with the requirements of the regulations/
Q 9.
Correlation of the requirements of the energy efficiency standards of Belarus and the requirements of the Technical Regulations of the EAEU "On the requirements for energy efficiency of energy-consuming devices"?
A 9.
The EAEU Technical Regulation "On Energy Efficiency Requirements for Energy-consuming devices" is under development and it is too early to talk about the correlation of requirements. The standards in the field of energy efficiency of household appliances of the Republic of Belarus were developed on the basis of the Regulations of the European Commission and cover both energy efficiency requirements and labeling requirements (consumer information).
To date, work is underway to introduce labeling requirements (informing consumers) into the technical regulations of the EAEU. Some appendices of the draft Technical Regulations of the EAEU have been developed on the basis of the old requirements of the Regulations of the European Union and do not take into account the changes and corrections made to the EU regulations (starting from 2014). In addition, the European Union is currently reviewing regulations on energy efficiency in connection with the release of the new EU Regulation 2017/1369 on labeling and consumer information. Regulations regarding energy efficiency requirements are also being revised.
If the EAEU Technical Regulation "On Requirements for Energy Efficiency of energy-consuming devices" is adopted in the existing version, the gap in basic requirements for energy efficiency and consumer information between the EAEU countries and the European Union will be 8-10 years.
Q 10.
The content of the test reports?
A 10.
General requirements for the test report.
The test report must contain reliable, objective and accurate test results, data on test conditions and measurement errors, a conclusion on the compliance of the tested equipment sample with the requirements of regulatory documents and design documentation and present accurately, clearly and unambiguously the test results and other relevant information.
The following information is indicated in the test report:
- name and address of the testing laboratory;
- registration number, date of issue and validity of the certificate of accreditation, name of the accrediting organization that issued the certificate (if any);
- the number and date of registration of the protocol of investigations, the numbering of each page of the protocol, as well as the total number of pages;
- date of receipt of the test application;
- date of the test;
- full name of the tested equipment and its parts (trademark, model and serial number of the tested equipment);
- place of testing;
- the name and address of the applicant organization or the surname, first name, patronymic of the customer and his address;
- climatic conditions of testing (temperature, humidity, pressure);
- the purpose of the tests;
- the test program (the scope of tests in the form of a list of items (sections) of the regulatory document on the requirements for the tested equipment and its components), (the test program can be given in the annex to the test report);
- description of the tested equipment (if necessary);
- detailed information about the manufacturer indicated on the equipment (if available);
- the source of information used to determine the operating modes of the device (operating manual), and the technical justification, if necessary, concerning the choice of the measured operating modes and the exclusion of any modes.
For devices with many functions or with options for including additional modules or additional devices, the protocol indicates the configuration of the device at which it was tested;
- a regulatory document for compliance with the requirements of which tests have been carried out (designation, STB, GOST, GES, etc.);
- a list of test equipment and measuring instruments used, indicating the name and type of test equipment and measuring instruments, the range and accuracy of measurements, data on the number of the metrological certificate or certificate and the date of the last and next certification and verification;
- values of indicators and tolerances (if necessary);
- the actual values of the test indicators indicating the measurement error;
- conclusion on compliance with the regulatory document for each indicator;
- information about the additional test report performed under the terms of a subcontract (if any);
- conclusion on the compliance (or non-compliance) of the tested equipment or its components with the requirements of the standards.
Q 11.
How to determine that a particular type of equipment belongs to household or office use?
A 11.
This question is within the competence of certification bodies, the answer to it will depend on the design, technical characteristics, purpose and application of the equipment.
Based on the provisions of various standards, equipment not related to household or office use:
equipment requiring regulated maintenance provided for in the regulatory and technical or operational documentation, performed at intervals and in the volumes specified therein, regardless of the technical condition of the product at the time of the start of maintenance, by trained, qualified persons (metrological requirements may be applied to measuring instruments installed in such equipment).
Q 12.
Do I need to provide energy efficiency certificates during customs clearance?
A 12.
Yes. It is required to provide certificates of both the national and the Eurasian system of technical regulation, regardless of the scope of certification.
Q 13.
STB "Energy efficiency. Marking" contain requirements for the availability of technical documentation.
In what form should the availability of technical documentation be ensured at the retail enterprise?
Is it possible to have technical documentation in electronic form with a printout at the request of the state supervisory authority?
A 13.
Technical documentation is a set of documents used in the design (construction), creation (manufacture) and use (operation) of technical objects.
Technical documentation is divided into several types:
- design documentation;
- operational documentation;
- repair documentation;
- technological documentation;
- documents defining the technological cycle of the product;
- documents giving the information necessary for the organization of production of the product; test reports of the product;
Technical documentation can also be called a technical passport, technical manual or technical literature.
Technical documentation within the framework of energy efficiency standards:
- operational documentation (user manual) - must be available at the point of sale, at the retail outlet;
- energy efficiency label and technical sheet - must be available at the point of sale, at the retail outlet;
- product test reports - copies of test reports certified with the seal and signature of the applicant for certification must be kept by the applicant for certification and the certification body, they are provided at the request of the inspection bodies, the presence of these documents is not required at the retail outlet;
- repair documentation - must be available at the manufacturer's service centers for maintenance and repair.
The remaining types of technical documentation are kept by the manufacturer and are provided at the request of the supervisory authorities. Additional technical documentation may also be requested by the certification body. We recommend that you provide the technical documentation required by the certification body to carry out the conformity assessment procedure. In this case, the supervisory authority will be able to apply to the certification body for the necessary documents bypassing the manufacturer or trade organization (dealer).
Q 14.
Requirements for information about products placed for sale on the Internet:
- on what website, in what format, for each nomenclature unit or for a group of products with similar characteristics?
Should there be a link on the packaging to the website?
A 14.
There are no requirements for the presence of links to the manufacturer's website on the product packaging in the energy efficiency standards. The application of a link to the packaging is at the request of the manufacturer.
Requirements for information about products placed for sale on the Internet are contained in the paragraph - requirements for sellers.
First of all, information about the energy efficiency of products should be posted on the seller's website next to technical advertising material about a specific product model. At the same time, information on energy efficiency must be provided to the seller by the manufacturer as part of the technical advertising material. Also, the manufacturer must provide the seller with a label of a certain format with information content in accordance with the requirements specified in the standards for labeling household appliances in the field of energy efficiency and a technical sheet in electronic form (in Russian), in a format available for posting on the Internet.
The label and technical sheet provided by the manufacturer in electronic form must be located on the display device in the immediate vicinity of the cost designation. The dimensions of the label should be proportional to the dimensions specified in the standard. The information on the label and the technical sheet should be easy to read and clear. The label and technical sheet can be arranged by means of a nest display^.
The graphic image used to activate the display of a label located by means of a nest display must:
- be represented by an arrow of the color corresponding to the energy efficiency class of the product;
- contain white letters and signs on the arrow corresponding to the energy efficiency class of the product. The font size of letters and signs should be equivalent to the font size indicating the cost of products;
- be presented in one of two variants, according to the figure below.
The graphic image used to activate the display of the technical sheet located by means of a nest display should be presented in the form of the phrase "Technical Sheet", which should be easy to read and clear.
Graphic images of the label and technical sheet, arranged by means of a nested display, must:
- displayed when the computer mouse clicks on the graphic image used for activation for the first time, or after hovering the cursor over the graphic image used for activation, or after touching the graphic image used for activation on the touch screen;
- displayed as a new browser window or as a modal dialog box;
- be able to touch zoom when displayed on the touch screen; close using the standard closing interface.
When selling products by the manufacturer through an information site on the Internet, he is also considered a seller, and the same requirements are imposed on him.
Since it is not assumed that the products placed for sale via the Internet, the buyer will be able to personally inspect, the information about the product posted on the seller's website is subject to the requirements specified in the section - "Information provided to the user in the absence of the possibility of inspection of the device". The content and procedure for providing information is different for each type of complex household appliances.
Q 15.
STB "Energy efficiency. Marking" contain requirements for the availability of a technical sheet.
In what form should the technical sheet be provided at the point of sale? Is it possible to have a technical sheet in electronic form with a printout at the request of the state supervisory authority?
A 15.
The standards that establish requirements for labeling the energy efficiency of household and office equipment, in the manufacturer's responsibility section, contain a mandatory requirement for the availability of a technical sheet that must be attached to each unit of equipment sold. The information set out in the technical sheet must be provided in the sequence specified in the relevant annex (links to the annexes vary depending on the standard). The technical sheet may be part of the equipment operating manual. One technical sheet may contain data on several equivalent models of equipment from the same manufacturer.
In the responsibility of sellers section, there are no requirements for the availability of a technical sheet at the point of sale. However, the technical sheet is part of the documentation that must follow with the equipment. Accordingly, at the request of the consumer, the technical sheet must be provided to the consumer by the seller. At the point of sale, the technical sheet must be together with all the documentation (operating instructions, etc.) accompanying the equipment (this is a requirement for the manufacturer). For convenience, the manufacturer can provide the seller with a technical sheet in electronic form, available for printing at the request of the consumer. Also, the technical sheet and the energy efficiency label should be posted on the manufacturer's website.
The technical sheet must necessarily be provided to the certification body during the conformity assessment procedure. All data specified in the technical sheet must be confirmed by the test reports.
Q 16.
The energy efficiency classes for some product categories established in the Russian Federation and the Republic of Belarus differ.
For example, the maximum energy efficiency class set for dishwashers in Russia is A, while the maximum energy efficiency class set for dishwashers in the Republic of Belarus is A+++.
At the same time, the two countries also differ in ways of communicating information about the energy efficiency class to the consumer: in Belarus - on the energy efficiency label in the form established in the STB, in Russia - on a label of any format placed on the product and on the transport (external) packaging of the product.
Please confirm that on the label according to the manufacturer's form placed inside the product, as well as on the transport packaging of the product, the Russian energy efficiency class may be indicated, different from the Belarusian energy efficiency class indicated on the energy efficiency label according to the form established in the STB.
A 16.
Standards on energy efficiency of household and office equipment have been adopted and are in force in the Republic of Belarus. Resolution of the Council of Ministers of the Republic of Belarus No. 849 dated 21.10.2016 introduced requirements for confirming compliance of this equipment with the requirements of specific standards of the Republic of Belarus. The standards of the Republic of Belarus establish requirements for energy efficiency classes, for the form of the energy efficiency label, for the technical sheet and for informing the consumer, as well as establish requirements for energy efficiency and minimum energy efficiency indices for admission to the market of the Republic of Belarus of household and office equipment.
On the label, in the technical sheet, technical documentation, in any technical advertising material, the energy efficiency class must be indicated in accordance with the requirements of the STB of the Republic of Belarus.
The design, format and content of the label must meet the requirements specified in the STB for a specific type of product.
Q 17.
Is it permissible, if the energy efficiency label on the package is printed on the packaging, and it is old-fashioned, to print the missing information with a self-adhesive label?
A 17.
The label must comply with the requirements of the standard. It is permissible to apply a self-adhesive energy efficiency label. The data indicated on the label must be confirmed by the test reports of the product for which the label is intended. Product manufacturers must ensure that the product is accompanied by a label, the format and content of which meet the requirements specified in the standard for a specific type of product.
Q 18.
What criteria will be used to divide (divide) the product line into different groups (for certification)?
For LCD TVs, microwave ovens, refrigerators, monitors, MFP devices (printers).
A 18.
The question lists various product groups, some of which require confirmation of compliance with STB 2248 (microwave ovens, refrigerators, monitors, MFPs (printers)). For televisions, the requirements are set in the standards of STB 2269 and STB 2479 standards. For the purposes of conformity assessment, choose a model of household and office equipment placed on the market with indicators similar to those of another model of household and office equipment placed on the market by the same manufacturer. For the STB 2248 standard, the choice of an equivalent model - see question No. 7 (section STB 2248 Electrical household and office equipment).
STB 2269 and STB 2479 (televisions);
For the purposes of conformity assessment, the selection of an equivalent TV model is based on the following parameters:
- energy efficiency class;
- matrix technology (plasma, IPS, etc.);
- device functionality (video recording, wired and/or wireless communication modules, DVD, receiver, Eco Sensor, etc.);
- the presence of additional low-power mode (network mode, etc.) - diagonal and the resolution of the screen (range diagonals in increments of 10," i.e., from 20" to 30", 30" to 40" etc SDTV, HDTV, 4K, etc.);
- features built-in processor (number of cores, frequency, power).
- the presence of a built-in battery;
- method of connection to the power grid (with an external adapter (power supply), built-in power supply);
- configuration of audio equipment.
In the presence of built-in communication modules (Wi-Fi, etc.), confirmation of compliance with the standards specified in paragraph 10 of the "list" to the resolution of the SMRB No. 489 of 21.10.2016 is additionally required.
Q 19.
At what stage should the energy efficiency label be attached to the device - before import to Belarus, before sale to the end user?
A 19.
The energy efficiency label must follow the equipment in the package, the requirements for applying the label in a prominent place apply to sellers, the label is applied only to those samples of equipment that are put up for sale at the point of sale.
Q 20.
Is it possible to store goods without an energy efficiency label in a dealer's warehouse in Belarus?
A 20.
The goods can be stored in the dealer's warehouse in the Republic of Belarus without a label applied to it, however, the corresponding energy efficiency label must in any case be in the packaging of each unit of goods.
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