[WANVE Regulatory Update] Countdown to DoC-to-CoC Transition: Which Machinery Products Will Be Affected Starting 2028?

Industry News

In 2026, EAC certification regulation in Russia and the Eurasian Economic Union (EAEU) continues to tighten. Starting July 1, Russia's SPOT system will be fully mandatory, with customs conducting real-time online verification against the FGIS certificate database, and the system performing automatic cross-checks. Without certification, declarations are directly rejected, goods are stranded at ports, and demurrage and storage fees accumulate by the day. Fines can reach 20% to 200% of the cargo value; in serious cases, entire containers are returned or even directly destroyed. EAC certification has become a hard "entry ticket."

At the same time, Eurasian Economic Commission Decision No. 36 has made major amendments to TR CU 010/2011 "On the Safety of Machinery and Equipment," significantly expanding the scope of mandatory CoC, and self-propelled machinery will be fully and mandatorily converted to CoC certification starting April 1, 2028. The EAC certification system is undergoing a structural reshaping.

I. What is EAC certification? What is the general process?

EAC certification covers the markets of five countries, including Russia, Belarus, and Kazakhstan, achieving "one certification, access to five countries." Depending on the product risk level, it is divided into two modes.

EAC DoC (Declaration of Conformity): enterprise self-declaration. For medium- and low-risk products, the core is the enterprise's own declaration that the product complies with technical regulation requirements. For most DoCs, compliant and valid test reports can currently be accepted and factory audits waived, with a streamlined process and no annual surveillance maintenance required during the validity period—provided that product risks are controllable and regulators trust enterprise self-declaration.

EAC CoC (Certificate of Conformity): third-party certification. For high-risk products, certification bodies intervene, and the certification process is more complex. Samples must be sent to an accredited laboratory within the EAEU for full-item testing, and factories must undergo on-site audits to verify production conditions, inspection methods, and the level of consistency control. CoC also requires annual surveillance audits; if one year is missed, the certificate is marked as suspended or invalid in the FGIS system, and customs clearance and sales are immediately blocked. The overall cycle usually lasts several months, with significantly higher costs; annual audits also mean continuous investment. The liability structure is also different: the certification body and the certificate holder share liability, and any flaw in any link may result in suspension or revocation of the certificate.

II. 2028: A large number of products will be mandatorily converted from DoC to CoC

In March 2026, the Eurasian Economic Commission adopted Decision No. 36, making major amendments to TR CU 010/2011 "On the Safety of Machinery and Equipment," with the core direction being tighter standards and a substantial expansion of the scope of mandatory CoC.

Key time point: April 1, 2028. From that date, the new list will be formally implemented, the mandatory CoC list will be greatly expanded, and a large number of machinery products originally eligible for DoC will be converted to mandatory CoC, newly covering a range of self-propelled machinery and equipment such as electric forklifts, stackers, construction and road machinery, earthmoving machinery, industrial tractors, and personal mobility devices (electric scooters, etc.).

Moving from DoC to CoC is not just a matter of swapping one certificate for another; it corresponds to threefold changes:

First, mandatory testing—samples are sent to designated laboratories for testing, and costs and timelines need to be reassessed;

Second, factory audits—certification bodies conduct on-site reviews of quality assurance capabilities, and passing the factory audit is a prerequisite for certificate issuance;

Third, post-certification surveillance—after the certificate is issued, periodic supervisory inspections must be accepted, representing ongoing investment.

The DoC path that originally took a few weeks may require several months reserved after conversion to CoC, and higher requirements are placed on production consistency.

III. Corporate compliance recommendations

The essence of this adjustment to the EAC certification system is the Eurasian Economic Union's comprehensive tightening of certification supervision for machinery and equipment. Rising compliance costs are inevitable, but this also provides export enterprises with a window to re-sort their product lines and certification strategies. It is recommended to adjust certification arrangements in accordance with the new regulatory requirements in a timely manner, self-check the product list, and confirm the applicable certification mode; if within the scope of mandatory CoC in 2028, test resources and certification arrangements should be planned in advance to avoid concentrated queuing near the deadline and affecting delivery schedules. It is also recommended to consult professional service agencies to clarify certification requirements and points for attention, ensuring a smooth compliance transition during the transition period.