EAC Approval for HVAC Systems: Household vs Industrial
The household and industrial routes for HVAC diverge sharply. Household equipment needs certificates under TR CU 004 and TR CU 020, which means a production audit and testing in a Customs Union laboratory, plus a TR EAEU 037 RoHS declaration. Industrial HVAC needs none of those: a declaration under 004, 020 and 010 suffices.
What counts as household HVAC?
Chillers and heat pumps, fan coil units, air conditioners, radiators, underfloor heating, supply and exhaust units, and other devices for heating, ventilating and air conditioning multi-room housing, private houses, cottages, villas and multi-room apartments.
To import these into the five EAEU member states, EAC approval is required. These products generally fall under TR CU 004, On safety of low voltage equipment, and TR CU 020, Electromagnetic compatibility of engineering equipment.
Which devices, by TN FEA code
| Device | TN FEA code |
|---|---|
| Fans | 8414 51 000 0 |
| Air conditioners | 8415 10, 8415 81 009 0, 8415 82 000 0, 8415 83 000 0 |
| Humidifiers, vaporisers, dryers | 8415 90 000 9, 8418 99, 8479 89 970 8, 8509 80 000 0 |
| Air cleaners, cooker hoods | 8414 60 000, 8421 39 200 9 |
| Electric heaters for animal breeding and plant growing; heating appliances for residential premises; electric radiators, fan heaters, convectors | 8436 21 000 0, 8516 21 000 0, 8516 29 |
| Electric fireplaces | 8516 21 000 0, 8516 29 500 0, 8516 29 910 0, 8516 29 990 0 |
| Underfloor heating systems | 8516 80 |
The household route
To apply the EAC mark you need a Certificate of Conformity to TR CU 004 (LVD) and TR CU 020 (EMC). That certificate carries two obligations a declaration does not:
- An audit of the production facilities
- Testing of the products in a laboratory accredited on Customs Union territory
On top of that, compliance with TR EAEU 037/2016, On restricted use of hazardous substances in electrical and electronics products, must be confirmed. The applicant conducts the necessary tests and registers a declaration, which is also a mandatory document for customs clearance.
That declaration can rest on factory test reports as in-house evidence, or on reports from third-party organisations: accredited or certified testing laboratories inside or outside the Customs Union.
The industrial route
Industrial HVAC systems require neither the TR EAEU 037 declaration nor certificates under TR CU 004 and TR CU 020.
Instead a declaration of conformity to TR CU 004 + TR CU 020 is permitted, supplemented for industrial equipment by TR CU 010, On the safety of machinery and equipment.
For that declaration the applicant conducts the necessary research and tests, and it may again be issued on factory test reports or on third-party laboratory reports, provided those take account of every requirement of the GOST standards the technical regulations call up.
Documents for the industrial declaration
Administrative:
- Authorised person agreement between the applicant and the manufacturer
- The applicant’s documents of incorporation, INN and OGRN
Engineering:
- Operation manual in the Union’s working language
- Test reports in the Union’s working language
- Safety justification
Who can be the applicant?
For both routes, only a company resident in the Customs Union. This is the constraint that shapes project timing more than any technical requirement, because the applicant carries the liability and cannot be appointed at the last moment.
Sources
- TR CU 004/2011, On the safety of low-voltage equipment, Eurasian Economic Commission
- TR CU 020/2011, Electromagnetic compatibility of technical means
- TR EAEU 037/2016, On restriction of the use of hazardous substances in electrical and electronic products
- TR CU 010/2011, On the safety of machinery and equipment
Frequently asked questions
Does industrial HVAC need TR EAEU 037?
No. Industrial heating, ventilation and air conditioning systems require neither a TR EAEU 037 declaration nor certificates under TR CU 004 and TR CU 020. A declaration of conformity to TR CU 004 and TR CU 020 is permitted, supplemented by TR CU 010 on the safety of machinery and equipment.
Who can be the applicant?
A company resident in the Customs Union, for both routes. A foreign manufacturer cannot register a certificate or a declaration in its own name; it appoints a resident applicant under an authorised person agreement.
Not sure which of these applies to your product? Send it and we will tell you
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