The Held-at-Customs Call

In February 2025, a ZF-450 carton forming machine bound for a confectionery packaging plant in Novosibirsk sat in Russian customs for 11 days. The shipping documents were complete, the invoice matched the packing list, and the CE declaration was included. The missing document: a valid EAC Declaration of Conformity (TR CU 010/2011 and TR CU 004/2016). The buyer had assumed CE marking covered EAEU requirements. It does not. The machine was eventually released after the importer applied for an expedited EAC declaration through a local certification body — at triple the standard cost and with 11 days of demurrage charges.

This is the most expensive misunderstanding in carton forming machine exports to Russia, Kazakhstan, Belarus, Armenia, and Kyrgyzstan. CE is a European requirement. The Eurasian Economic Union (EAEU) requires EAC certification under a completely separate regulatory framework.

Which TR CU Regulations Apply

Carton forming machines fall under two main Technical Regulations of the Customs Union:

TR CU 010/2011 — On Safety of Machinery and Equipment. This is the primary regulation covering all industrial machinery. It requires a risk assessment, a safety justification document, and compliance with specific essential safety requirements including guarding design, emergency stop circuit architecture, and control system reliability. For carton forming machines, the critical sections are: mechanical hazard protection (moving folding arms, pinch points at belt transfers), electrical safety (control cabinet IP rating, grounding continuity), and noise level limits. The Zray ZF series ships with Category 3 (EN ISO 13849-1 equivalent) safety circuits on all models as standard, which exceeds the TR CU 010 minimum of Category 2 for this machine class.

TR CU 004/2016 — On Safety of Low-Voltage Equipment. Applies because the machine operates on 380V AC input. Covers insulation resistance testing (minimum 1 MΩ at 500V DC test voltage), dielectric strength testing (1,500V AC for 60 seconds), and protection against indirect contact.

TR CU 020/2011 — Electromagnetic Compatibility. Required because the machine contains variable-frequency drives and servo motor controllers. Radiated emissions and conducted emissions testing per GOST 30804.6.3 and GOST 30804.6.4. The Siemens drives on Zray machines include built-in EMC filters compliant with these standards, but the complete machine must still be tested as an assembly because cable routing and grounding can affect emissions.

Certification Paths: Declaration vs Certificate

For carton forming machines, the applicable path is an EAC Declaration of Conformity (not a Certificate). The Declaration is issued by the manufacturer or the importer (the “applicant” must be a legal entity registered in the EAEU) based on test reports from an accredited laboratory.

Required documents for the Declaration package:

• Machine technical passport with specifications, operating manual in Russian
• Safety justification document (risk assessment per TR CU 010 Annex)
• Test reports from an EAEU-accredited laboratory for electrical safety, EMC, noise, and mechanical safety
• ISO 9001 certificate of the manufacturer (not mandatory but significantly shortens the review process)

The Zray factory in Dongguan maintains a pre-prepared technical file in Russian for all standard models. We contract with a Moscow-accredited laboratory (RUS Accreditation-certified) that reviews the documentation package and issues test reports within 7 working days. The importer then registers the EAC Declaration on the Federal Service for Accreditation (Rosakkreditatsiya) portal. Total timeline from document submission to registered Declaration: 12 to 16 working days.

Three Mistakes That Delay EAC Clearance

1. Assuming CE covers EAC. We repeat this because every delayed shipment involved this assumption. CE and EAC are independent systems. A machine can have CE but cannot legally enter the EAEU without EAC.

2. Missing the Russian-language operating manual. TR CU 010 explicitly requires operating documentation in the official language of the importing member state. An English manual with a Russian summary page does not satisfy this. The full manual — all safety warnings, all maintenance procedures, all electrical schematics — must be in Russian.

3. Incorrect applicant entity. The EAC Declaration applicant must be registered in the EAEU. If your end customer is the importer, they must be the applicant. If you are using a distributor, the distributor is the applicant. A Chinese manufacturer cannot be the applicant directly. Confirm who will act as the applicant before starting the certification process.

Budget 8,000 to 15,000 USD equivalent for the complete EAC compliance package including testing, documentation translation, and Declaration registration. Start the process a minimum of 6 weeks before the planned shipment date. The 11 days of demurrage in Novosibirsk cost the importer more than the certification would have cost if started on time.