Most companies learn that a declaration of conformity is required at the moment the cargo is already at the border. Some of the documents can no longer be obtained by then — not because they take long, but because they are issued at a stage that has already passed.
Conformity assessment is not a formality and not “one more piece of paper”. It is a condition for lawful circulation of goods in the Eurasian Economic Union. Without a conformity document the goods can be neither sold through major retail, nor supplied under a tender, nor listed on a marketplace that verifies documents. So the question is not whether the document is needed, but when to start obtaining it.
On the status of the information in this article
Set out below are the general principles of the EAEU technical regulation system and the typical requirements importers encounter. The specific document list for a specific product is determined by its HS code and by the applicable technical regulation. This article does not replace a consultation with an accredited certification body — it is there so that you understand what to ask and at which stage.
The Eurasian Economic Union sets mandatory requirements for products through the Customs Union technical regulations (TR CU). If a product falls within the scope of a regulation, it may circulate in the territory of all the union’s countries only with a document confirming conformity with that regulation.
The key property of the system: the document is valid across the whole union, not in a single country. A correctly issued TR CU declaration of conformity covers Kazakhstan, Russia and Uzbekistan alike, in the part where the relevant regulations apply. That matters if you plan to sell beyond a single country.
The flip side: the requirements are uniform and mandatory. They cannot be circumvented by “coming to an arrangement” at local level — what is checked is not the presence of a stamp but the presence of an entry in the register.
Both forms confirm conformity, but they differ in who bears responsibility for accuracy.
| Feature | Certificate of conformity | Declaration of conformity |
|---|---|---|
| Who issues it | An accredited certification body (third party) | The applicant itself, registered with an accredited body |
| Who is responsible for accuracy | The certification body and the applicant | The applicant — and only the applicant |
| Is laboratory testing mandatory | Yes, in an accredited laboratory | Depends on the declaration scheme set out in the regulation |
| Validity | Set by the body, usually up to 5 years | Up to 5 years; for some categories not set |
| What it covers | As a rule, serial production | A batch or serial production |
The key point of responsibility
Under a declaration, responsibility for the accuracy of the declared information rests with the applicant. That means that if the declaration states characteristics the goods do not meet, it is your company that answers, not the body that registered the document. That is precisely why inspection before shipment is not a formality but protection against a document that formally exists yet does not match the contents of the batch.
There is no universal list of “goods that need a certificate”. The regulations are grouped by product type, and applicability is determined by the product description and the HS code. Even so, there are categories where importers systematically underestimate the requirements.
In the construction group, according to the accredited bodies of Kazakhstan, mandatory conformity assessment covers among others:
Construction equipment additionally falls under TR CU 010 “On the safety of machinery and equipment”. That covers concrete mixers, compressors, pumps and generators — equipment bought not as a consumable but as a fixed asset.
Separate regulations apply to lubricants, fluids and a number of other groups — for example TR CU 030/2011 for lubricants, oils and special fluids.
The main mistake in this section
Determining the requirements from the category name. “Building materials” is not a product group in technical-regulation terms. Ceramic tiles, dry building mix, steel profile and a light fitting are four different sets of applicable regulations, even though all four are bought as “building materials”.
There is only one correct order of operations: first the HS code of the specific product, then the applicable regulations, then the document list. Do it in the reverse order and you will end up with documents for the wrong thing.
The general scheme looks like this:
Determining the applicable regulations from the HS code
At this step it is established whether the product falls under mandatory requirements and by which scheme conformity is confirmed. Everything that follows depends on it: the composition of the documents and whether laboratory testing is needed.
Application and document collection through an accredited body
The processing is done not directly and not “through an acquaintance”, but through a body accredited in the EAEU system. It is that body which enters the record in the register.
Testing in an accredited laboratory
Some schemes require sampling and laboratory testing. This affects the timeline: testing cannot be sped up on request, it can only be started earlier.
Registration of the declaration and entry in the register
From the moment of registration the document is valid throughout the EAEU. A declaration can be issued for a batch or for serial production; validity is up to 5 years, and for certain categories it is not set.
On the timeline
The market offers processing “within 2–6 weeks”. We give this as a market benchmark and do not confirm specific figures: the timeline depends on the product category, the need for laboratory testing and the completeness of the documents the factory provides. Plan from the longest scenario, not the shortest: a delay at this stage means goods that have already been made and paid for sitting idle.
In correspondence with suppliers and in documents you come across various abbreviations, and they do not mean the same thing. The difference is fundamental: some relate to mandatory requirements, others to voluntary ones.
| Designation | What it is | Mandatory? |
|---|---|---|
| TR CU | Customs Union technical regulation — the body of mandatory requirements itself | Mandatory if the product falls within the scope of the regulation |
| EAC | The EAEU market circulation mark applied to products that have passed conformity assessment | Mandatory for products covered by the regulations |
| ST-KZ | Certificate of conformity of Kazakhstan’s national system | Depends on the category; applicability must be checked separately |
| CT-1 | A certificate used within a number of procedures, including for confirmation purposes on import | Situational; the specific purpose must be clarified for your case |
Separately: do not confuse TR CU with GOST
TR CU are the mandatory requirements of the EAEU. GOST and the standards of the ST RK system follow, as a rule, different logic: some relate to voluntary certification, some to confirmation under national procedures. A voluntary GOST certificate does not replace a mandatory TR CU declaration, and vice versa.
A practical sign: if a supplier sends a “GOST certificate” in answer to a question about TR CU, he has either not understood the question or is answering a different one. Either way, the correspondence needs to start again — from the HS code.
This is the main section of the article. The problem is not that processing takes time, but that some actions are possible only on the factory side and only before shipment. Once the goods have gone, you no longer have the lever to make the supplier finish something — he has already been paid, and the goods are already outside his jurisdiction.
Test samples taken from the same batch
Laboratory testing is carried out on samples, and the sample must correspond to the goods you are importing. If a sample is produced separately “for the certificate”, the document formally exists but protects nothing: when the batch’s conformity is checked, it confirms nothing. After shipment it is no longer possible to take a sample from the same batch — the batch is in transit or in a warehouse, not in the workshop.
What it means: the question of samples has to be closed before serial production starts.
The factory’s documents for raw materials and components
Some conformity assessment schemes require information about materials and component suppliers. That data exists only at the manufacturer and only at the time of production. Six months later the factory may no longer have either those raw-material batches or the documents for them.
What it means: material data is requested together with the samples, not separately.
A specification matching the goods actually shipped
The declaration contains characteristics, and the characteristics come from the specification. If the specification in the contract and the goods in the container differ, you receive a document that does not match the contents. That cannot be fixed retroactively — you can only bring the goods into conformity or re-issue the document to match the actual characteristics.
What it means: a mismatch between the specification and the batch is not a dispute with the supplier, it is your risk as the applicant.
Applying the circulation mark and mandatory marking
The EAC mark and mandatory marking codes are applied to the product or the packaging. Technologically this is done at the plant or on the packing line. Applying them at the destination requires either opening and repacking the whole batch, or a separate production operation for which there is nowhere to do it in the importing country.
What it means: the method of applying the marking is agreed with the factory before the order is placed, not after arrival.
Why “we will sort it out later” does not work
The logic of postponement rests on the assumption that processing is work with a document. In practice a large part of the work is work with the production process: which samples were taken, what is written in the specification, how the packaging is marked, what data the factory provided. The production process ends at the moment of shipment. Everything that belongs to it has to be settled before that moment.
The order of operations. All the points relate to a stage that finishes before the order is placed with the factory.
Obtain the HS code and determine the applicable regulations
This is the entry point. Without it, any further action is guesswork. For regular supplies it is worth fixing the code with an advance classification ruling.
Draw up the document list for your product
Not a general list of “what exists”, but a list for your category: what is issued, in what form, for a batch or for serial production, and whether laboratory testing is required.
Establish what is required from the factory — and write it into the contract
Sampling, material data, the exact specification, the method of applying marking. These are contract terms, not requests in correspondence: a request can be ignored, a term cannot.
Check the mandatory marking timetable for your category
If marking comes into force within the term of your supply, it changes both how the packaging is produced and the lead times. More detail in the separate piece on marking.
Start the processing before production, not before shipment
Between “before shipment” and “before production” there is a difference of several weeks — precisely the ones you will be short of later. Laboratory testing cannot be sped up, but it can be started earlier.
Short conclusion
Conformity assessment is part of the purchase, not part of logistics. The document is drawn up from data that exists only at the moment of production: samples from the batch, the composition of materials, the specification, the marking. When the goods leave the factory, that data becomes unavailable along with them. The cheapest way to solve this is to raise it before the order is placed.
We identify the applicable TR CU regulations, draw up the conformity assessment procedure, verify the document list and fix the requirements on the factory in the contract. Certificates are issued by accredited bodies of Kazakhstan and Uzbekistan — we do not sell certificates, we prepare for them.
Send the specification or a description of the item. We will determine the applicable technical regulations, draw up the conformity assessment procedure and tell you which documents need to be obtained and what requirements to put to the factory — before the order is placed. The first review is free, and it commits you to nothing.
