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Electrotechnical products marketed in the Eurasian Economic Union (EAEU) must undergo conformity assurance procedures before 1 March 2020 to prove their compliance with the EAEU Technical Regulation 37/2016 on the Restriction of Hazardous Substances (RoHS) for electronics and radio-electronic products. 

 As of March 2020, RoHS certification will be mandatory for products being sold in Russia and countries in the Customs Union including Belarus, Armenia, Kazakhstan and Kyrgyzstan.

Technical Regulation (TR) no. TR 37/2016 restricts the content of six substances: 

• Lead
• Cadmium
• Mercury
• Hexavalent chromium
• Polybrominated biphenyls 
• Polybrominated diphenyl ethers

The requirement is to ensure the protection of life, human health, and the environment. Specific warning actions will also be in place so that users of the products are not misled about dangerous substances.

There is a range of products that will need to meet the new requirements, but the regulation and its specific Annexes should be reviewed to ensure the correct compliance is followed.

What products will RoHS affect?

Products subjected to EAEU RoHS TR 037/2016 include:

1. Electrical apparatus and appliances for domestic use
2. Electronic computers and devices 
3. Terminal telecommunication devices
4. Electrical office equipment
5. Electronic tools 
6. Lighting
7. Musical equipment
8. Game machines
9. Cash registers, ATMs, and electronic information devices
10. Ticket printing machines and ID readers
11. Electrical cables and wires
12. Automatic switches and residual current devices
13. Fire and security detectors

RoHS Declaration of Conformity (DoC) will be mandatory on products already on the market that have EAC approval for EMC/Safety.

What documentation is required to be RoHS compliant?

Documentation needed includes:

• RoHS Test report or EU RoHS DoC (CE DoC showing RoHS)
• Bill of Materials (BOM)
• ISO for factories
• User manual in Russian
• Local representative agreement

Does RoHS need to be included on my DoC?

For CE marking, RoHS does need to be on your DoC if it applies to your product.  For Russia, one way of gaining RoHS certification is to submit your signed CE DoC showing the RoHS directive. If you don’t have a CE DoC for RoHS, you will need to submit a RoHS test report.

The Element advantage

Element’s Global Market Access (GMA) team carries out RoHS certification on electronics to assure conformity with EAEU TR 37/2016, European Directive 2011/65/EU (RoHS 2) and similar requirements of other countries/regions. For more information, please contact us today.