Declaration of Conformity: What You Need to Know
A declaration of conformity with EEU technical regulations is a document submitted by the applicant and certifying the conformity of the declared products with EEU technical regulations, as well as the fact that they may safely be released onto the market. Unlike the certificate of conformity, the declaration can only be issued on a mandatory basis. The certification is a form of assessment carried out by the applicant, i.e. by the first party.
Who can apply for a declaration of conformity?
Any natural person (individual entrepreneur) or legal entity registered in the EEU that is a manufacturer or a seller or is acting as an overseas manufacturer may apply for a declaration of conformity. The declaration cannot be accepted by an overseas manufacturer directly. In this case, the application needs to be carried out through a person/entity authorized by the overseas manufacturer (for serial production) and/or the seller (importer) (for consignments).
Which goods require a declaration of conformity with EEU technical regulations?
To begin with, you need to make sure that your products require a conformity assessment in the form of a declaration of conformity in addition to being subject to particular technical regulations. For example, no declaration of conformity is needed for frozen fish or vinegar but it is mandatory for oranges.
What are the requirements for a testing laboratory?
The choice of laboratory is determined by the conformity assessment scheme. Please note that testing at your own laboratory (that may or may not be accredited) is only allowed under the 1D scheme. For most conformity assessment schemes, testing is performed at an accredited laboratory included in the Register of accredited conformity assessment bodies. Please check the website of the Federal Accreditation Service (Rosaccreditation): https://pub.fsa.gov.ru/ral. Your products should fall under the specified scope of accreditation. Please check the accreditation status of the laboratory: is it valid, suspended, or annulled? Some technical regulations also require that the accredited laboratory be included in the EEU Unified Register of Accredited Conformity Assessment Bodies (its national part).
How do I perform sampling?
Sampling for testing may be performed directly by the applicant; there is no requirement for this to be done by an accredited body. Our managers will advise you on the required number of samples. This is determined depending on the scope and methods of testing.
An additional service is also available on demand at «ROSTEST Moscow»: sampling by one of our experts performed at your facility.
What paperwork do I need to file for the Declaration of conformity to be issued?
The documentation required for the registration of a declaration of conformity is specified in regulatory and legislative acts: technical regulations for the product, the Decision of the Government of the Russian Federation No. 936 dated June 19, 2021 «On the registration, suspension, renewal and termination of declarations of conformity; their annulment and suspension; the renewal, termination, and suspension of certificates of conformity», the Decision of the Commission of the Customs Union (KTS) No. 621 dated April 07, 2011 «On the Provision regarding the use of model schemes to assess (confirm) the conformity with the technical regulations of the Customs Union», the Decision of the Board of the Eurasian Economic Commission No. 44 dated April 18, 2018 «On model schemes of conformity assessment», the Decision of the Board of the Eurasian Economic Commission No. 41 dated March 20, 2018 «On the registration, suspension, renewal, and termination of declarations of product conformity with the technical regulations of the Eurasian Economic Union», and other legislative acts.
Our managers will advise you on the documentation and information required to issue the declaration and walk you through the procedure.
How much time do I need to get a Declaration of conformity?
The time frame for issuing a declaration of conformity varies depending on the type of product to be certified, the number of metrics evaluated, and the duration of testing. As a rule, the procedure takes up to several days or weeks.
What is the term of validity for a Declaration of conformity?
The term of validity for a declaration of conformity is determined by the applicant. However, this does not mean that you may specify any time frame convenient to you. The term of validity is subject to the provisions of specialized technical regulations.
May I alter the Declaration after it has been registered?
Making changes to a declaration that has been registered is not allowed. If alterations need to be made, a new declaration is registered and the old one is terminated.
However, in some cases a new declaration may be registered without having to prepare an additional package of certification materials or perform a new round of testing; for example, if there are changes in the name of the legal entity.
How realistic is getting the Declaration on my own?
Starting from January 1, 2021, certification bodies no longer have the right to register declarations of conformity. In accordance with the new regulations on registering a declaration and maintaining the register of declarations, the applicant should:
- directly register declarations of conformity using the specialized automated registration service of the Federal Accreditation Service (Rosaccreditation);
- sign declarations using an electronic digital signature of the authorized person designated by the applicant.
At first glance, the procedure is very simple. You form a documentation package, enter your information using your personal account, and register the Declaration of conformity.
In reality, however, not everything goes to plan. The Rosaccreditation service may not always be available due to technical errors; you might erroneously submit an incorrect declaration or simply not possess the particular skill set required to proofread the accompanying documentation and provide the necessary information. For example, the applicant may not always correctly determine whether the chosen testing method corresponds to the product metrics to be tested; whether a particular laboratory is able to perform a particular kind of testing; and decide on other important issues that demand competence and experience.
Thankfully, certification bodies still have the opportunity to help applicants:
- analyze and form a complete documentation package and gather all the information required to register a declaration;
- identify the products and develop a testing program;
- organize sampling and testing;
- prepare a correct template corresponding to all legal requirements. All the applicant has to do is enter the declaration into the system and register it in one click.
One option is to register the declaration on your own, which would require a thorough analysis of technical regulations, conformity assessment legislation, norms pertaining to registering and drawing up the declaration, as well as entering it into the corresponding unified register, regulations on testing laboratories and testing protocols.
Another option is to contact us. Our competent experts will answer any questions you may have concerning the declaration of conformity!
We will organize product testing and help you register your declaration; in addition, we will issue an official document from «ROSTEST Moscow» detailing all the legislative requirements pertaining to declaring conformity: why and on what grounds particular regulations were used, why testing protocols are adequate and correspond to current legislation, both in terms of safety performance and methods of testing. Using such a document as part of your certification materials is a recipe for success. And if any questions arise, we are always happy to help.
