Comments from EU relating to Draft Technical regulation on alcoholic products safety.

Labeling requirements.

The EU has the following concerns regarding labeling provisions: The EU is of the opinion that the indication of the mass concentration of sugars for wines (Article 6.16 sub 6) should not be required since there is no such requirement at international level. The EU considers that the indication of the month and the year of tirage for collection sparkling wines and high quality collection sparkling wines (Article 6.16 sub 9) should not be required as it brings no added value to the consumer and could be misleading. Instead, the vintage year should be indicated. The indication of the date of bottling is irrelevant for some products such as sparkling wines. Therefore the EU would like to suggest to Russia that only the production date is mentioned in order to avoid misleading consumers (Article 6.16 sub 13).The indication of the storage conditions is unnecessary for products containing more than 10% by volume of alcohol (Article 6.16 sub 14).With regard to the size of the health warning (which must cover 20% of the label) the EU would like to receive clarification as regards the reasons for setting out this requirement and, in particular whether more feasible size requirements have beenconsidered.7 In this respect, the EU would like to recall Article 2.2 of the TBT Agreement, which states that: "Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade". The EU would like to receive clarification of what is meant by "the indication of the document in compliance with which the alcoholic beverage is produced" as this is unclear. In any case, this requirement does not seem to have any equivalent in the international practice (Article 6.16 sub 17).The requirement that the information on the label should be provided in Russian and in the languages of the other members of the Customs Union is excessive and unjustified (Article 6.21).

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Comments from EU relating to Draft Technical regulation on safety of chemicals.

Labeling requirements.

It is not clear to the EU what is meant in Article 7, paragraph 1 by "the name of the document in accordance with which chemical products have been manufactured (when available)" and why this would have to be indicated on the label. Could the Russian authorities provide some examples? It is not clear that the labelling requirements concur fully with the GHS rules, in particular the various elements such as pictograms, signal word, hazard and precautionary
statements. Are these all contained in GOST standard 31340 which is referred to in paragraph 5 of Article 7 and in Article 8?

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Customs Union Technical regulations on safety of devices operating on gaseous fuels ( CU TR 016/2011). EAC certificate

Effective from 15th February  2013 by Council Decision of Eurasian Economic Commission on December 9, 2011 number 875.

Products covered by regulations:

  1. Gas-consuming equipment for cooking, heating and supplying hot water
    • Heaters
    • Cookers
    • Burners
  2. Automatic block burners
  3. Gas devices intended to be installed in the equipment
    • Automatic valves
    • Regulators
    • Thermostats
    • Flexible conneсtors

Types of documents needed for conformity compliance:

  1. Certificate of conformity. Costs from 800 EUR. Validity period up to 5 years.  
  2. Declaration of conformity. Сosts from 500 EUR. Validity period up to 3 years.  

 List of the documents needed to issue certificate of conformity:

  1. Test reports,
  2. Description,
  3. Photos,
  4. European certificates (for some categories of parts)

Full list of devices subject to conformity compliance can be downloaded here: in Russian.

Safety justification

Safety justification contains risk analysis and information on safety measures which should be taken during the life cycle of the equipment. Safety justification is a mandatory document for the certification according to Customs Union Technical Regulations on safety of pressure devices (CU TR 032/2013) and on safety of machines (CU TR 010/2011).

The designer of the equipment must keep the original of the safety justification, the manufacturer must keep a copy of the document. Safety justification must be developed in accordance with standard GOST R 54122-2010.

Safety justification chapters

  • General description of the device
  • Requirements for product reliability
  • Requirements for personnel
  • Risk analysis
  • Requirements for safety during commissioning, operating and utilisation
  • Requirements for quality management during commissioning, operating and utilisation

To order safety justification

Certification Quality Conformity sp. z o.o. is offering to develop safety justification in accordance with CU TR 032/2013 and CU TR 010/2011 for the purpose of certification. The cost of the service is 800 EUR. Lead time – 10 working days. Please, contact us with your products details for the confirmation of price.

Technical passport.

Technical passport is a mandatory document for the certification according to the Customs Union Technical Regulations on safety of pressure equipment (CU TR 032/2013). It's used for the identification of the equipment.
Depend on the equipment, passport will consist of different chapters. In general, passport contains information about technical parameters and characteristics, recycling and certification.
Template of the passport for pressure vessels can be found in standard GOST 52630. Template for the vessels with pressure less than 0,05 MPa. Template of passport for the vessels with pressure more than 0,05 MPa.

Technical passport and other technical regulations.

Passport is mandatory document not only for the CU TR 032/2013 but for some other regulations also. The technical regulations on safety of elevators ( CU TR 011/2011) also establishes requirements to the passports, in this case for lifts. Even though there is no requirement for passport in the technical regulations on the safety of machines, usually complex machinery is provided with passports. Examples: cranes, mine equipment.

Developing of technical passport.

Certification Quality Conformity sp. z o.o. is offering to develop technical passports in accordance with CU TR 032/2013 for the purpose of certification. The cost of the service is 800 EUR. Lead time – 10 working days. Please, contact us with your products details for the confirmation of price.

What to do next?

descriptionSend us technical description, picture and customs code.
analyze We will analyze it and prepare the dedicated offer.
sign-contractWe sign a contract and after prepayment start working on certificate.
testing,factory visit We do all the formalities: factory visit (if needed), testing, document creation.
Issue certificate Our certification body issue certificate and you are free to export in Customs Union.

In order to provide you with a quote, we will need some basic information from you such as a product description, customs code (HS code) and the country of destination.

If you are looking to open your export trade to a greater area of Europe, contact Certification Quality Conformity today for a quote. We are working from 8.00 till 16.00 GMT +1. Feel free to send us an inquiry, email or make call.

Certification Quality Conformity sp. z o.o
Nadmorski Dwor 16/B/5,

80-506, Gdansk, Poland.
KRS: 0000329248, REGON: 220786734, NIP: 584-267-5273

info@cqc.com.pl
T: +48 (58) 3541263

M: +48 509959591