On November 26, 2021, a public discussion began on the draft of amendments to the decision of the Board of the Eurasian Economic Commission (EEC) No. 293 dated December 25, 2012, which approved unified forms of EAC certificates and EAC declarations of conformity according to the requirements of technical regulations of the Eurasian Economic Union / Customs Union (TR EAEU / TR CU).
The public discussion will last 45 days and should end on January 10, 2022.
The draft of the amendments has the following goals:
1. Simplification of procedures for replacement of the EAC certificates and EAC declarations of conformity when making changes that do not affect product safety.
2. Removing unnecessary financial burden from applicants.
3. Minimizing the risks of importing products into the EAEU that do not meet the mandatory requirements.
4. Simplification of product traceability for the end user.
Consolidation of the clauses on electronic form of EAC certificates and EAC declarations of conformity
First of all, important amendments concern the inclusion of the clauses on electronic permits in the decision. New clauses are added, where it is clearly stated that the electronic record of the certificate and declaration of conformity in the unified register is a document on conformity assessment in electronic form. Such documents have equal legal force with documents on paper. At the same time, it is important that in case of a contradiction in information, priority is given to an electronic document.
In this regard, the draft amendments also indicate that it is allowed to issue permits only in electronic form without issuing a paper copy. In this case, a note is made in the unified register that the document was not issued on paper and that a paper version cannot be obtained.
This will significantly help applicants and relieve the financial and time burden in terms of the need to replace a paper document, for example, if it is lost.
Adding QR Code to EAC Certificate and EAC Declaration of Conformity Forms
The draft of the amendments involves the addition of QR codes to the paper versions of certificates and declarations of conformity, which will allow a quick transition to the electronic versions of the documents.
At the same time a note is added that such a code is indicated in case its formation is envisaged in the national part of the unified register.
This will become a solution to the problem with dishonest applicants as the electronic version of the document displays its actual status, which cannot be quickly checked in a paper version. In addition, this solution will help simplify product traceability for the end consumer.
Adding GLN and GTIN code requirements
Requirements for the obligatory presence of GLN codes in unified registries are established by Decree of the Government of the Russian Federation No. 1856 dated November 18, 2020 but have not yet been consolidated in decision No. 293 dated December 25, 2012. The draft of the amendments will finally eliminate this gap.
So, in the project it is established that the GLN code or the global location number (if available, at the choice of the applicant) is included in the field with information about the product.
If available, at the option of the applicant, the international GTIN code can be also indicated in the certificate and declaration of conformity.
Supplementing information about the evidentiary materials based on which the certificate was issued
In the form of a certificate of conformity, the field with the grounds for issuance is planned to be supplemented with the following information: number and date of execution of the production status analysis report, the name of the certification body and the registration number of the accreditation certificate (this information will remain mandatory for the field "Certification body").
Clarification of additional information
As additional information, the draft of the amendments involves supplementing information about the registration number and the date of registration of the certificate / declaration of conformity to be replaced, with the entry "issued instead" (in case of replacement of the certificate / declaration of conformity), as well as information on the distribution of the certificate for serial production manufactured from the date of fabrication of the samples that have passed the tests, indicating the information on the date of their manufacture.