TU when registering SS and DS. Is it necessary to specify?

Ministry of Agriculture of the Russian Federation Licensing

Expert opinion

Import license of the Ministry of Industry and Trade

TR TS EMS

Refusal letter to customs

FSB notification Customs Union base

Hello everyone

Do I need to upload Technical Specifications (TU) when registering a declaration of conformity and a certificate of conformity in the TR CU system to a Russian
manufacturer?

Let's figure it out.

We know that in 41 decision of EAEC stipulates such a requirement, among other documents required to load in the register of the Federal service for accreditation (FSA), the applicant
is not required to provide a document according to which developed and made something or other equipment (products, and so on) in accordance with applicable standards and so on.

But!
By the way, we also remember that our Russian GOST standards remained only for a certain number of goods. Everything else implies the presence of Technical Specifications (technical specifications) and, accordingly
, for most of the goods, when registering declarations and certificates, the applicant seems to have to provide Technical Specifications.

Is this really the case or not?

Let's turn to the 44 decision of the EAEC, where it is already more precisely and in detail described what exactly the applicant can provide in this situation.
And we see that this includes Technical conditions (description), that is, in other words, the presence of Technical conditions for the registration of the declaration of conformity and certificates of conformity for the Russian
manufacturer is not necessary at the moment. It is mandatory to provide technical data, that is, a description, some design or operational documentation in which the main characteristics,
safety measures, instructions for use and everything like that will be displayed.
This is a mandatory requirement, but the availability of Technical conditions is not a mandatory requirement, if there is, then immerse, if not, then it's okay. Legally, this requirement is not displayed anywhere.
Also, in practice, after talking with a number of certification bodies (OS) and testing laboratories (IL), we found out that at the moment there has not been a single case in which the document of conformity in the field of TR CU
cancelled or suspended due to the lack of Technical specifications for the Russian manufacturer.

And that's it for me.

Thank you all.

While.

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