Certification or Declaration Under TR CU 018
TR CU 018 provides three forms: vehicle type approval, certificate of conformity and declaration of conformity. The last two apply mainly to components and spare parts, and the difference between them is where responsibility sits and how much third-party control applies.
What are the three conformity assessment forms under TR CU 018?
TR CU 018/2011, On the safety of wheeled vehicles, provides for:
- Vehicle type approval
- Certificate of conformity
- Declaration of conformity
Certification and declaration are used mainly for vehicle components and spare parts. Whole vehicles go through type approval.
What does certification involve?
Certification means an accredited certification body takes the file, sends the samples to an accredited laboratory, and puts its own name on the certificate next to yours. The body may also assess production or the quality system. Responsibility is shared with the certification body, which is why this route carries stricter control. It applies to products with higher safety risks.
What does a declaration involve?
With a declaration, you declare compliance with the requirements under your own responsibility. The declaration is entered in the FSA (Rosakkreditatsiya) register in your name, and the testing can be done in your own laboratory or a third-party one, and you assemble the test reports and documents yourself.
Side by side
| Certification | Declaration | |
|---|---|---|
| Certification body | Mandatory involvement | Not involved; the declaration goes into the FSA register |
| Testing | Accredited laboratories | Own or third-party laboratories |
| Evidence base | Assembled with the body | Assembled by the applicant |
| Responsibility | Shared | Applicant’s alone |
| Control level | Stricter | Simplified |
The row that matters commercially is the last but one. A declaration is cheaper and faster precisely because the applicant carries the liability that a certification body would otherwise share.
What decides which applies
- The product type
- Its intended use
- Its impact on vehicle safety
- The requirements and product lists in TR CU 018
Incorrect selection can lead to document rejection, penalties and market access problems, and the error surfaces at customs or during surveillance rather than at application.
Sources
- TR CU 018/2011, On the safety of wheeled vehicles, Eurasian Economic Commission
- Eurasian Economic Commission Board Resolution No. 77 of 14 July 2015, product lists under TR CU 018
Frequently asked questions
What are the conformity assessment forms under TR CU 018?
Three: vehicle type approval, certificate of conformity, and declaration of conformity. Certification and declaration are mainly used for vehicle components and spare parts; whole vehicles take type approval.
What distinguishes certification from declaration?
Certification means an accredited certification body takes part, the testing happens in accredited laboratories, the body may also assess production or the quality system, and responsibility is shared with the body. With a declaration, you declare compliance under your own responsibility and assemble the test reports and documents yourself.
What decides which form applies?
The product type, its intended use, its impact on vehicle safety, and the requirements and product lists in TR CU 018. It is a determination, and an incorrect selection can lead to document rejection, penalties and loss of market access.
Not sure which of these applies to your product? Send it and we will tell you
Related articles
Which Products Fall Under TR CU 018
Categories M, N and O, chassis, and safety-related components. Plus what modification triggers, and the three vehicle types excluded outright.
EAC Approval for Automotive Spare Parts
A four-year certificate, mandatory local testing, part numbers written in full in the annex, and an annual inspection that re-tests the product.
TR CU 020: Electromagnetic Compatibility Explained
What falls inside the EMC regulation, which products certify and which declare, the three certification schemes, and the two exclusions worth knowing.
