The three-TR overlap
| TR | Scope | Route | Testing |
|---|---|---|---|
| TR CU 004/2011 | Low-voltage equipment safety | Certificate (scheme 1С serial) | IEC 60950 / 62368 baseline |
| TR CU 020/2011 | Electromagnetic compatibility | Certificate (scheme 1С serial) | CISPR 32 / 35 emission + immunity |
| TR EAEU 037/2016 | Restriction of hazardous substances (RoHS) | Declaration | Substance analysis report + supplier declarations |
A single EAC certificate under scheme 1С listing both TR CU 004 and TR CU 020 was issued by an accredited body in Almaty. A separate declaration under TR EAEU 037 was registered by the Kazakh importer. Total document set: one certificate, one declaration, ready for customs.
Factory audit
Scheme 1С requires a production-site audit by the certification body every year of the certificate's 5-year validity. We coordinated the on-site audit in Shenzhen: 3 days on the manufacturing floor, focused on ESD control, incoming quality control on components covered by TR EAEU 037, and traceability of the certified model range. The audit report cleared the file with two minor observations (both closed within 10 days).
The classification battle
A Wi-Fi smart controller can plausibly be declared under three TN VED headings: 8517 (transmission apparatus), 8536 (electrical apparatus for switching), or 8543 (electrical machines and apparatus, having individual functions). Duty rates and applicable EAC scope differ across all three. We filed for an advance classification ruling from KGD (Предварительное решение о классификации) covering the three flagship SKUs. Ruling issued at 8517 62 000 9 — locked for three years across every customs post in Kazakhstan.
Routing and clearance
Routing choice: block-train service Shenzhen → Xi'an consolidation → Khorgos gauge change → Almaty inland terminal. Total transit: 21 days. Cleared under IM-40 procedure, green channel (the importer's compliance history under a different product line qualified). All three containers released within 12 hours of arrival at the customs post.
What ships in every follow-up order
- The 5-year EAC certificate (TR CU 004 + TR CU 020) — no re-testing required for the covered model range.
- The TR EAEU 037 declaration — re-issued when the bill of materials changes.
- The advance classification ruling — cited in Field 44 of every DT-1.
- The origin certificate (Form A) — for GSP-eligible duty rate where applicable.
- The digital traceability registration when the product moves into a Chestny Znak-marked category.