Introduction and procedure duration
TR EAEU 043/2017 regulation (“On requirements for fire safety and fire extinguishing systems”, also known as EAC TR CU 043/2017, ТР ЕАЭС 043/2017, CUTR 043/2017, TRTS 043/2017) is one of the most demanding in the EAC marking system. Its entry into force meant, for a lot of companies, a new technical barrier. Compared to the old fire regulation 123-ФЗ (that was almost fully replaced), it is much less permissive. It does not permit to include more than a family of products in a single certificate (and in a single set of tests). And since it requires more tests, it also increases the costs.
There is another critical factor: the few accredited laboratories are really strict in all the phases of the certification, from the documentary part to the technical tests, including a full company audit.
In this article we’ll see all the phases of the certification according to the TR EAEU 043/2017. There are a lot of steps to be passed to get the Certificates. Usually, the procedure requires between 4 and 6 months. Right now, the 2022 sanctions against Russia may not directly block the export of some products, but the logistics tend to complicate the certification, since the delivery of the samples takes more time than in the past.
👉 Need to know if you can export to Russia or Belarus, according to the EU sanctions? Check the last Council Regulation: EU 2022/1269.
Applicability of the TR EAEU 043/2017
The EAC Fire Safety Regulation applies to:
- Fire extinguishers.
- Protective materials.
- Fire trucks.
- Detectors and alarms.
- Extinguishing installations and systems.
- Personal protective equipment.
- Firefighter special protective clothing.
- Fire barriers.
As can be seen, the vast majority of these products are for fire extinction. However, the products that act as a “barrier” against fire are very relevant since they can be manufactured by a wide range of industries. In practice, the certification of insulators is perhaps the most frequent.
The applicability of the regulations is defined by a list of all HS codes subject to mandatory certification. This list also indicates how the assessment must be carried out, being the EAC Certificate of Conformity the most common form, well above the EAC Declaration of Conformity.
The tariff heading is a necessary but not sufficient condition for the applicability of the TR EAEU 043/2017. Other factors are relevant: for example, the exclusion of all the products intended for a marine use. An insulator used in an oil platform cannot be certified according to TR EAEU 043/2017, unless the manufacturer declares that the product is intended also for a land use. Many Russian clients want the fire certification at all costs, even forcing its applicability.
👉 Want to check the list on your own? Request it at email@example.com and we will send it to you.
The only possible “certification” of a product excluded from the TR EAEU 043/2017 is the Letter of Exemption or Rejection or Negative Decision issued by a Russian Certification body. In this document, the body refuses to open a certification process and so allows the product to be exported freely to the Eurasian Union.
EAC Fire Safety Certificate Price
After verifying the applicability of the regulations, the technical laboratory informs the client about the set of tests that must be carried out. The cost of the certification is proportional to the type and number of them.
The tests are not detailed in the TR EAEU 043/2017, but each test has its own technical reference regulation, normally of the GOST type, but also STB. Here are some of the most important GOSTs:
- GOST R 53280-2009. “Automatic fire extinguishing installations. Extinguishing agents”.
- GOST R 50588-2012. “Foaming agents for fire fighting. General technical requirements and test methods”.
- GOST R 53313-2009. “Molded electrical installation products. Fire safety requirements. Test methods”.
- GOST R 53295-2009. “Means of fire protection for steel structures. General requirements. Method for determining the fire retardant efficiency”.
- GOST R 51057-2001. “Fire fighting equipment. Portable fire extinguishers. General technical requirements. Test methods”.
- GOST R 53325-2012. “Fire fighting equipment. Technical means of fire automation. General technical requirements. Test methods”.
An insulator available in more than a thickness or density will be tested in various formats. This will increase the costs. In the same way, a company that wants to certify a wide catalog of smoke detectors must know that the tests will be at least one per family.
👉 Do you want to know what test methodology applies to your product? Write us and we will help you to find the corresponding GOST regulations.
Drawing up the Zayavka
The application (Заявка in Russian) is signed by the applicant and formally starts the process. It states the contact details of the manufacturer and the products description, with the models’ names or the references numbers. In the technical details, the final use must be well indicated.
If the zayavka is rejected (as said above) the procedure ends and a Exemption Letter is issued. Thanks to the this Letter, the Customs clearance can be done.
If the zayavka is accepted, it’s time to collect the technical docs in a specific format.
Drawing up the technical file
The so-called “Technical Regulations” (Технологический регламент in Russian) is a document, fully in Russian, that the manufacturer must submit. It provides the technical data and a very specific info depending on the type of product.
For example, it is needed to state the category an insulator belongs to, based on the testing GOST norm. This is the case of the GOST R 53295, that defines 7 product classes based on the time it takes a steel beam to reach 500ºC. A steel beam insulated with a 4th group product will reach 500ºC at least in 60 minutes.
It may also be needed to provide instructions on how to test the product, taking into account the test methodology. If a product requires some tools to be applicated, they must be sent to the lab.
Safety, transport and storage info cannot be missing in the technical file.
In the best case, depending on the type of product and the tests to be performed, it may be enough to submit an operating manual or some assembly instructions.
Production Analysis (Company Audit)
Before the tests, the manufacturer has to be audited. The procedure (called in Russian “Акт o результатах анализа состояния производства”) is quite similar to ISO 9001.
As a result of the Covid-19 pandemic, audit is carried out remotely. Firstly providing the required documents and then in an online session. Through Zoom or Teams, the Russian inspectors may ask for clarifications or extra info to the audited company. Documents must be translated into Russian and an interpreter has to attend to the online session. The duration is between two and three hours.
The Production Analysis is focused on the following points:
- Quality Policy. Procedures for continuous improvement.
- Control of incoming materials and accessories. Suppliers’ quality policy. Tests on incoming materials and components.
- Production process of the products to be certified. Controls. Verification of possible defects (non-conformity). Quality control. Equipment maintenance.
- Measurement and testing devices. How the metrological control is carried out? List of equipments and their calibration.
- Non-conforming products. Marking and related procedures.
- Post-production tasks. Storage and packaging. Handling of complaints.
In each area, the person or department responsible has to be indicated.
Also remotely (and recording the session as well) the auditors will guide the selection of the samples to be delivered to Russia. They will provide clear instructions to the person responsible of the task. The size and other features of the samples are advised prior to the sample act.
For this operation, as well as for the previous step, the company has to hire an interpreter.
After collecting and packing the samples (with the customs documents), they can now be sent to the laboratory where they will be tested. The shipping has to be tracked, so a Customs Declaration, the called GTD, must be issued.
This is indeed the only official proof of the shipment. The GTD must be kept carefully, in case of being required by the authorities.
Now it’s finally the time to check the conformity of the products to the TR EAEU 043/2017. After completing the tests and the technical protocols, the laboratory shares the results with the client.
Results can be provided in different formats: Excel sheets with data or media (videos or photos). There will be photos of all the steps: the preparation phase, the test development and the final appearance of the samples after testing.
With the positive results of the tests (and of course of the Production Analysis as well), the Certification Body can issue the Certificates. In the EAC countries, there are very few accredited bodies for the TR EAEU 043/2017. As a consequence, this step is like a funnel that often delays the end of the procedure.
Certificates for serial production with 3 or 5 years of validity are subject to an annual control. This requirement has a fee and may lead to new tests or a new audit, depending on the type of product.
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You can send us the basic documentation (tariff headings and technical sheets) by email (firstname.lastname@example.org) or you can contact us for a preliminary online meeting.