EAEU RoHS: EAC compliance For EEE Manufacturers Operating in Eurasia

If you’re selling electronics in Russia, Kazakhstan, Belarus, Armenia, or Kyrgyzstan, you need more than just CE marks — you need EAC compliance under TR CU 037/2016 (aka EAEU RoHS).

Let’s break it down — no fluff, just what matters.

What Is EAEU RoHS (TR CU 037/2016)?

EAEU RoHS is the Eurasian equivalent of EU RoHS, restricting hazardous substances in electrical and radio-electronic equipment. It came into force on March 1, 2020.

> It’s also called Russia RoHS or EurAsia RoHS — but the regulation is officially known as TR CU 037/2016.

If you’re not compliant, you can’t sell your product legally in the EAEU market.

Scope: What Products Are Covered?

EAEU RoHS applies to 12 categories of products:

• Household appliances
• Personal computers & accessories
• Telecommunications equipment
• Lighting & office electronics
• IT & network devices
• Power tools
• Leisure & sports electronics
• Vending machines & gaming terminals
• POS/cash management systems
• Fire alarms
• Circuit protection (RCDs)
• Cable products

> ⚠️ Products not covered: military, aerospace, temporary R\&D equipment, and devices under other technical regulations.

Restricted Substances (by Homogeneous Material)

EAC Mark = Proof of Compliance

You’ll need to affix the EAC mark (Eurasian Conformity Mark) on every product that meets RoHS and other EAEU technical regulations.

No EAC = No customs clearance. Period.

Multi-country substance compliance becomes more manageable with RoHS compliance software that helps track changing regional requirements.

EAEU RoHS Documentation: What You Need

To get EAEU RoHS certified, you’ll need:

• RoHS test report (can be EU-based, but must be accepted by EAEU CBs)
• Declaration of Conformity (DoC) – signed by a local rep
• Bill of materials (BOM)
• ISO 9001 certificate (if available)
• User manual in Russian
• Risk assessment per IEC 63000

> All of this must be stored in a technical file, valid for up to 5 years.

EAEU RoHS Certification Pathways: 2 Options

Option A: Self-Declaration (via local representative)

• Low-risk products
• Valid in-country RoHS lab tests or accepted EU tests
• Submit technical file and DoC to an accredited body

Option B: Certification via Third-Party Lab

• High-risk or complex products
• Requires in-country testing
• Certificate issued after inspection + technical doc review

Published in the EAEU Database

Once your DoC is approved, it’s published in the EAEU conformity database — making your compliance public and traceable to authorities, customs officers, and customers.

EAEU RoHS Enforcement & Penalties

How it's enforced:

• Market surveillance by member states
• Customs inspections on import
• Random product testing
• Verification of EAC mark and registered DoC

What happens if you fail EAEU RoHS:

• Product seizure or bans
• Border rejection
• Fines
• Brand blacklisting

Who's Responsible for EAEU RoHS?

• Manufacturers: Must prove conformity, prepare documentation, and apply the EAC mark.
• Importers: Must ensure imported products are compliant and registered.
• Local Representatives: Required to sign the DoC if the manufacturer is outside the EAEU.

Final Word: Don’t Wing EAEU RoHS

The EAEU isn’t just mirroring EU RoHS. It’s building its own system — and if you don’t adapt, you’re off the shelves.

Transparency, documentation, and local partnerships are key.

Acquis can help. From compiling your technical file to registering your DoC — we make RoHS compliance in Russia and the EAEU frictionless.

> Speak to our EAEU RoHS expert now