EAC Certificate, Declaration of Conformity, or State Registration: What Is Required for Imports into Armenia?

When importing goods into Armenia, businesses often need to determine whether the product requires an EAC conformity certificate, a declaration of conformity, or a state registration certificate. These documents serve different regulatory purposes, and the applicable requirements depend on the product's characteristics, intended use, and relevant EAEU technical regulations.

Choosing the wrong document, or failing to obtain the required evidence of compliance, may result in additional testing, unexpected expenses, customs clearance delays, or restrictions on placing the product on the EAEU market.

This guide explains the differences between the main conformity documents, how to check their validity, and what importers should do before shipping goods to Armenia.

1. What is EAC, and why is it important?

EAC (Eurasian Conformity) is the unified mark of circulation for products on the Eurasian Economic Union market. It indicates that the product has undergone the applicable conformity assessment procedures under the technical regulations that require the EAC mark.

It is important to distinguish between:

• The EAC mark: a conformity marking placed on products or their packaging as required by the applicable regulations.
• A conformity assessment document: a certificate, registered declaration, or another legally prescribed result of conformity assessment.

The expression "EAC certificate" is widely used in commercial practice, but EAC itself is not a separate type of certificate.

The presence of the EAC mark does not automatically establish that all documents required for a particular import shipment are valid and applicable.

2. When is a certificate of conformity required?

A Certificate of Conformity confirms that a product meets the relevant requirements through a conformity assessment process involving a competent, appropriately accredited certification body.

Depending on the technical regulation and certification scheme, the procedure may include:

• Product identification and technical document review.
• Laboratory testing of samples.
• Assessment of manufacturing conditions where required.
• Issuance and registration of the certificate.
• Periodic surveillance when required by the applicable scheme.

Mandatory certification may apply to particular categories of toys, electrical equipment, and other products.

The general product name alone is not enough to determine whether certification is mandatory. The scope and conformity assessment provisions of the relevant technical regulation must be reviewed.

3. What is a declaration of conformity?

A Declaration of Conformity is another legally established form of conformity assessment. Under the applicable procedure, the applicant declares that the product complies with the relevant requirements based on the required supporting evidence.

The evidence may include technical documentation, laboratory test reports, and other materials specified by the applicable assessment scheme. The declaration must be registered in accordance with the relevant rules.

The key distinction between certification and declaration concerns the roles and responsibilities of the applicant, certification bodies, and other participants.

A declaration does not mean that testing or compliance verification is unnecessary. The specific requirements depend on the technical regulation and conformity assessment scheme.

For example, declarations of conformity are required for many categories of food products. EAEU Technical Regulation TR CU 005/2011 also provides for declarations for relevant categories of packaging.

4. What is a state registration certificate?

A State Registration Certificate (SGR) confirms that a product has undergone the state registration procedure required by the applicable legislation.

State registration is particularly relevant to certain products subject to sanitary, hygiene, or health-related safety requirements.

Depending on the applicable rules, it may be required for:

• Specified categories of specialized food products.
• Certain types of perfumery and cosmetic products.
• Particular chemical products and household chemicals covered by relevant sanitary rules or product lists.

Not all food products and not all cosmetics require state registration. The precise category and legal requirements must be verified.

A state registration certificate cannot automatically be replaced by an ordinary certificate or declaration of conformity. Some products may also be subject to several overlapping regulatory requirements.

5. What are the main differences between these documents?

The required assessment procedure is established by law. An importer cannot simply select whichever document is easiest to obtain.

6. How can importers determine which document is required?

Determining the applicable requirements involves several steps:

1. Identify the product: exact description, brand, model, composition, technical characteristics, and intended use.
2. Review the EAEU HS classification: the tariff code is important but may not be sufficient on its own.
3. Identify applicable technical regulations: more than one technical regulation may apply to a single product.
4. Determine the conformity assessment procedure: certification, declaration, state registration, or another legally prescribed process.
5. Consider the import purpose and customs procedure: commercial imports and samples intended for testing may be treated differently.

For example, certain electrical equipment may need to be assessed under TR CU 004/2011 on low-voltage equipment safety, TR CU 020/2011 on electromagnetic compatibility, and other applicable regulations.

7. Which EAEU technical regulations are commonly relevant?

This table is for general guidance only. It does not mean that every product in a category automatically requires a certificate or declaration.

The scope, exclusions, and conformity assessment procedures must be determined under the individual technical regulation.

8. Can an importer use an existing certificate from the supplier?

A supplier may already hold a certificate of conformity or a registered declaration. However, receiving a copy does not automatically establish that the document is suitable for the intended import.

The importer should verify:

• The document number and registration details.
• Its validity period and current status.
• The manufacturer, product description, trademark, and model.
• Whether it covers serial production or a particular shipment or batch.
• The applicant's details and the legal basis on which the importer may use the document.

The import procedure established by EEC Council Decision No. 130 of November 12, 2021, includes rules concerning who may use conformity assessment documents to demonstrate compliance to customs authorities.

For serially manufactured products, authorized use of an existing document may be possible in circumstances provided for by the applicable rules.

9. How can an EAC certificate or declaration be verified?

The EAEU maintains a unified register of issued certificates of conformity and registered declarations of conformity.

Importers should compare the document number, applicant, manufacturer, product details, validity period, and status with the registry information.

EAEU Unified Register of Certificates and Declarations of Conformity

State registration certificates are checked through the relevant state registration records or competent authorities.

Important: A document's presence in the register does not automatically mean that it covers every related product model or shipment.

10. Can products be imported without a conformity assessment document?

The answer depends on the product category, import purpose, and customs procedure.

EEC Council Decision No. 130 of November 12, 2021, establishes situations where the general rules on demonstrating compliance with technical regulation measures at import do not apply or where specific exceptions are available.

Subject to the applicable requirements, special treatment may be available for samples used for testing, used products, and certain spare parts.

However, an exception from presenting a conformity assessment document during a particular customs procedure does not automatically authorize unrestricted sale of the product on the EAEU market.

11. What documents should be prepared for an initial review?

Before requesting a compliance assessment, importers should prepare, where applicable:

• A Commercial Invoice or preliminary product list.
• Detailed product descriptions and technical specifications.
• Brand, model, manufacturer, and country of manufacture.
• Material composition or ingredients where relevant.
• Manufacturer documentation, product photographs, and labeling samples.
• Existing conformity certificates, declarations, test reports, or state registration certificates.
• Importer details and the intended use of the goods.

This is a practical preliminary review checklist, not a universal statutory document list for every import.

12. Three common mistakes made by importers

Mistake 1. Treating CE marking as a replacement for EAC

European CE marking does not automatically replace conformity assessment required under applicable EAEU technical regulations.

Mistake 2. Assuming every product needs an EAC certificate

Depending on the product, the required procedure may involve certification, declaration, state registration, another assessment method, or no such mandatory requirement.

Mistake 3. Checking compliance documents only after shipment arrival

Where additional testing, applicant authorization, or manufacturer information is required, missing documents can complicate the customs clearance process.

13. What does REGULUS GROUP recommend?

Before purchasing and shipping goods, businesses should:

1. Review product classification and technical characteristics.
2. Identify the relevant EAEU technical regulations.
3. Determine the required conformity assessment procedure.
4. Verify the validity and applicability of supplier documents.
5. Assess whether laboratory testing, state registration, or additional permits are required.

REGULUS GROUP assists importers with preliminary documentation reviews, assessment of import compliance requirements, coordination of required documentation, customs consultations, and customs clearance procedures in Armenia.

Identifying the correct conformity documents before shipment helps businesses reduce avoidable costs, delays, and regulatory risks.

Legal basis and official sources

• Applicable EAEU and Customs Union technical regulations.
• EEC Council Decision No. 130 of November 12, 2021, on the import procedure for products subject to mandatory conformity assessment.
• Customs Union Commission Decision No. 299 of May 28, 2010, on sanitary measures, where applicable.

Official EEC guidance on import compliance and conformity assessment documents

EAEU Unified Register of Certificates and Declarations of Conformity

Professional customs consultation

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