Lighting HS Codes
The Russian market of lighting is literally flooded with Chinese-made lamps, which predominate in the lower segments of the market. The products of German, Italian, Dutch and French manufacture, on the other hand, due to their quality and the attractiveness of their most iconic brands, have good penetration rates in the world of luxury. This presence is increasing, despite the unfavorable situation.
When we talk about luminaires, we are essentially referring to the 9405 family and, in particular, to the most used tariff items:
940510: Chandeliers and other electric ceiling or wall lighting fittings, excluding those of a kind used for lighting public open spaces or thoroughfares (“fixed lamps”)
940520: Electric table, desk, bedside or floor-standing lamps (“portable lamps”)
940540: Other electric lamps and Lighting fittings (this code is the most used for lamps for gardens or outdoors)
The tariff code itself does not automatically define the certification procedure, that is determined by very specific variables, in particular these two:
- Expected use
- Light typology
Domestic Use Lighting
The intended use for the luminaires is surely the most relevant information since it determines the type of procedure to be followed.
Lighting for domestic use require the issuance of an EAC Certificate of Conformity that involves sending samples to Russia, as well as inspection (or now video inspection) at the manufacturer’s facilities. In addition, the EAC Certificate of Conformity is subject to an annual renewal/audit mechanism that can lead to more tests and more inspections or video inspections.
Leaving aside a very rare exception, the Certificate must be issued according to TP TC 004/2011 (download here all TR CU and TR EAEU), the Eurasian Low Voltage regulation, very similar to the European LVD.
Depending on the type of light, compliance with another Regulation, TP TC 020/2011 (Electromagnetic Compatibility), from which incandescent lamps are excluded, must be achieved or not. In other words, domestic LED lamp lighting requires compliance to both low-voltage and EMC regulations, in the form of the EAC Certificate of Conformity.
The aforementioned exception concerns battery-operated LED lamps. In this case, the Certificate of Conformity must be carried out only on the basis of EMC regulations, which will reduce the tests to be carried out and therefore the costs of the certification.
General or industrial use lighting
The most common non-domestic luminaires are industrial lamps and street lamps. In these cases, the manufacturing company avoids the complexity of the procedure indicated above since the EAC regulations prescribe the issuance of a simpler EAC Declaration of Conformity. The regulations involved are TR CU 004/2011 (LV) and TR CU 020/2011 (EMC) as well.
Fixed or portable lamps
As already mentioned, “movable” (or “portable”) luminaires and fixed luminaires have different tariff headings. That means that often models produced by the same manufacturer are certified (or declared) separately: on the one hand the tariff heading 940510 and on the other hand, 940520. This widespread practice is not based on an obligation of law since it is actually possible to include both types of luminaires in a single document: simply indicating the 9405 family.
Having two Certificates of Conformity may be interesting from a commercial point of view, but it is not strictly necessary. Nonetheless, it is highly recommended to carry out two technical protocols and test the two types of lamps: in this way, full compliance with the EAC regulations is accredited without having to bear the costs of two certificates.
Declaration of Conformity 037/2016 (RoHS) for lighting
Regardless of the intended use, all types of luminaires are subject to the Regulation on hazardous substances in electrical equipment, the well-known ТР ЕАEU 037/2016.
The Declaration is normally carried out based on the 1D scheme, which allows obtaining it in quick times.
For inquiries about this relatively recent requirement and for the certification of lighting in general, freely contact us by email: firstname.lastname@example.org, providing the following information:
- tariff heading
- intended use
- type of lighting (fixed / portable)
- type of light (LED, incandescence, etc.)