Foreign Manufacturer

A Foreign Manufacturer is a company or person that develops, manufactures or places products on the market under its own name or trademark outside the Eurasian Economic Union (EAEU). Manufacturers from the European Union, Switzerland, the United Kingdom, the United States, China or other third countries are subject to specific regulatory requirements when their products are to be placed on the market in Russia, Belarus, Kazakhstan, Armenia or Kyrgyzstan.

The Technical Regulations (TR EAEU / TR CU) require Conformity Assessment for numerous product groups. Depending on the product and the applicable requirements, an EAC Certificate or EAC Declaration may be required. The foreign manufacturer provides, in particular, the technical information and documentation required for the assessment of the product.

Depending on the respective product and procedure, important tasks of a foreign manufacturer may include:

  • provision of the Technical Documentation,
  • preparation of technical descriptions,
  • provision of a Test Report or other required test evidence,
  • provision of the required evidence relating to Product Safety,
  • support during the conformity assessment procedure
  • as well as provision of the product information required for the respective procedure.

In EAC conformity assessment procedures, a foreign manufacturer without an establishment within the EAEU cannot act as the Applicant or Declarant itself in every procedure. Where the applicable requirements require an economic operator established within the EAEU, the respective function must be performed by an appropriately authorized party established there.

An important regulatory function may be performed by the Authorized Representative. Depending on the respective procedure, an Importer or other appropriately authorized economic operators may also be involved. The specific allocation of roles depends on the applicable conformity assessment procedure and regulatory requirements.

The foreign manufacturer plays an important role in ensuring the accuracy and completeness of the technical information, product data and documentation it provides. Incorrect technical information, inconsistent documentation or insufficient evidence may result in additional queries, testing or delays during conformity assessment.

The following topics are particularly relevant for foreign manufacturers:

Particularly for machinery under TR CU 010/2011, industrial installations, pressure equipment under TR CU 032/2013, electrical equipment and equipment for potentially explosive atmospheres under TR CU 012/2011, extensive regulatory requirements may apply. Complete and consistent technical documentation facilitates the respective conformity assessment procedure.

Typical problems encountered in conformity assessment procedures for products of foreign manufacturers include:

  • missing required documentation,
  • incomplete test evidence,
  • incorrect product classification,
  • a missing or insufficient Safety Justification,
  • incorrect marking
  • as well as unclear responsibilities between the economic operators involved.

Early regulatory assessment, complete technical documentation and a clear allocation of the required roles can help avoid additional queries, unnecessary effort and delays in the Certification Procedure.

We support foreign manufacturers in preparing for and carrying out the required EAC certification and declaration procedures. This includes Product Classification, preparation of the Technical Documentation, coordination of required testing and coordination with certification bodies and other parties involved within the Eurasian Economic Union.

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