- Equipment variation based on the same circuit engineering
- FSS notification for module or final device
- FSS notification for telecom equipment
- Who signs the application forms?
- Is CU certification scheme mandatory for all telecom devices?
- Who issues and registers CoC and DoC?
- Labeling language
- Who is the responsible for the product?
- Who owns original DoC?
- Who can use the CU TR certificate or declaration registered?
- Is it obligatory to certify spare parts?
- Who holds an original?
Equipment variation based on the same circuit engineering
Q. Our customer is planning to make variants based on the same engine i.e. same electronics, antenna design and so on. The only difference will be the outlook and the casing. They want to know is it needed to approve the device again in this case.
A. In accordance with EAEU or Russian national regulation, the equipment should be identified by its marking plate, package and documentation. If the manufacturer leave all of them the same (model, trademark, factory, country and any other identification feature), in this case there is no reason to renew any certificates or declarations. If any of them is changed, it’s other product not specified in your certificate or declaration.
FSS notification for module or final device
Q. I have been checking the document sent by you and I did not find information regarding if FSS notification is required for a module or if it’s only needed for final devices?
A. FSS notification is document used to import and clear customs only. In accordance with EAEU | CU regulation, the equipment could be identified by its marking plate, package and supplying documentation. So the model, trademark, factory name, country and any other identification feature specified on equipment should be absolutely the same as specified at your certificate or declaration. Therefore, approve the module if a module goes onto EAEU market or final device if it goes onto EAEU market.
FSS notification for telecom equipment
Q: If telecom device is already declared (DoC registered by FAC) and additionally contains some encryption function but the customer does not obtain the FSS notification for this device, could the customer meet problems?
A: FSS notification for encryption is obligatory to clear customs.
Who signs the application form?
Q. Who signs the application form — overseas manufacturer or its local representative company?
A. In accordance with EAEU or Russian national regulation, the applicant and holder should be a local company registered on EAEU or Russian territory only. Therefore, the application forms should be obligatory signed by local representative company. If a manufacturer assign our company as a local representative, we need to get an application form signed by manufacture or any company authorized by manufacturer to start the certification or declaration procedure.
Is CU certification scheme mandatory for all telecom devices?
Q. Is CU certification scheme mandatory for all telecom devices except when they are modules?
A. Not at all. The obligation of CU TR certification or declaration scheme is determined by Article 1 of LVE or EMC CU | EAEU regulation (Scope of regulation). There is no criterion as telecom equipment there. For example, smartphone or tablet should be certified but USB Wi-Fi dongle should be declared in accordance with EMC regulation.
Who issues and registers CoC and DoC?
Q. Who issues and registers CoC and DoC?
A. CoC (Certificate of Conformity) is issued by an accredited body and registered by the federal authority.
DOC (Declaration of Conformity) is issued by a declarant (= local representative company) and registered by the federal authority.
Q. What language is used for labeling, documentation etc?
A. Manufacturer, factories, their addresses, country, model and trademark can be in English.
Equipment type, voltage and wattage, safety requirements, warning notes should be in Russian.
Who is the responsible for the product?
Q. In case a device has done harmful damage (malfunctioning, interferences etc). Who is responsible of the product? Who must to pay for this?
A. The manufacturer is responsible for CU TR requirements but local company pays the penalty in case if there are unsatisfactory findings. In accordance with agreement between the local company and manufacturer, the manufacturer should indemnify the loss of representative company.
Who owns original DoC?
Q. Is it relevant who owns original DoC: it can be the local representative or the manufacturer?
A. Legally, it should be the local representative only. An overseas manufacturer cannot be as owner of declaration.
Who can use the CU TR certificate or declaration registered?
Q. Who can use the CU TR declaration or certificate registered?
A. Any company can use the one if it is issued for serial production.
Q1: For devices that as spare parts which are not able to work by itself as a final product and it is not intended to be commercialized independently, for example devices that will be installed into cars.
A1: In accordance with CU TR 020/2011 EMC regulation it should be approved obligatory, there are 2 way to do it:
— to test and approve with a car together;
— to test and approve it independently.
Q2: For spare parts to repair the product already certified
A2: No need in this case. It’s enough to submit the certificate for end-product to clear customs and letter that’s spare part for repair service.
Q: Can the manufacturer get the original of CoC or DoC if the holder is resident of EAEU?