The implementation of the Customs Union (CU) and later the Eurasian Economic Union (EAEU) first raised many questions among manufactures of machines and equipment or EPC contractors. Besides an understandable knowledge gap, the main question was whether and how the quality requirements of the member states of the Eurasian Economic Union – Russia, Kazakhstan, Belarus, Kyrgyzstan and Armenia – could be fullfilled. There is often a real concern about the new Technical Regulations (TR) which comes from assumptions or sometimes bad experiences in the past.
Another problem arose during the certification process itself: Who is exactly responsible for liability and warranty of foreign machines?
These are just a few problems that ALPHA engineers are confronted within their daily work.
To give a clear picture for discussion, the advantages and possible improvements should be briefly described, based on the daily work of our ALPHA colleagues and my work and leadership role in various regulatory technical committees and business associations.
The advantages are evident:
- A large, relatively uniform economic area with many equal market accesses was formed and the fragmentation of the five member countries was almost eliminated. It is now possible to supply a large economic area with a certificate of conformity, so the pressure vessel approval with TR 032/2013 (“On Safety of Pressure Vessels and Pressurized Equipment”) does not have to be made individually for each country, but is valid for all member states;
- The technical regulations were partly adapted to international norms and standards, as the example of TR 012/2011 (“On Safety of Equipment intended for Use in Explosive Atmospheres”) clearly shows;
- A uniform, detailed and publicly open register of all certificates and declarations of conformity has created more transparency. I believe that this should also serve as a model for other economic areas;
- With the new licensing of all testing institutes, a “proliferation” of pro-forma testing institutes was radically abolished. This resulted in a high quality leap and reliability of the test results;
- The simplified rules improve market opportunities for all participants and keep those out of the market who save costs in quality and safety.
- Last but not least, the quality of manufacturers from the Russian Federation or Belarus, for example, is made more transparent to the outside-market of the EAEU.
Where there is a light, there is also a shadow: Some points are still unclear or need to be clarified. A few examples are intended to illustrate this:
- There is still no stable system of norms and standards of the Eurasian Economic Union in correlation with local norms and standards of the member states, such as for steel structures, fire safety, high-voltage equipment or measuring instrument registration (Pattern Approval);
- It is necessary to clarify better the terms “complete” and “incomplete” machines or – only as an example – the technical term “interlinked machine”;
- A list of products and components that are subject to mandatory approval should be drawn up for all TRs. (e.g. TR 020/2011 “On Electromagnetic Capability” does not have such a list);
- It is not always clear to manufacturers of foreign measuring instruments which are subject to individual state supervision and which are not (Pattern Approval). This complicates market access for the manufacturers.
The initial fears have hardly been confirmed. In short, the system always works better.
The few selected points show that the system of Technical Regulation has led to improved market access for foreign manufacturers and EPCs and at the same time to better transparency of the conformity assessment procedures. At the same time, it has also improved the quality of machinery and equipment within the five member states through clear regulations.
In order to comply with technical compliance, it is advisable to work with experienced companies that know all the standards of the Eurasian Economic Union and the countries of origin in detail and implement them professionally and in compliance with the rules. This saves you time and money and opens up a profitable market.
ALPHA and its experienced engineers are at your side for all Technical Regulation/ certification questions and projects – whether machine or plant – in the Eurasian Economic Union.