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Do I need to make a new document on conformity assessment when a change of address?

Sometimes companies are faced with a situation where it is necessary to change the address, ownership, name or other details, and those details were noted in the documents on conformity assessment (certificates and declarations of conformity), and the validity of the document has not yet expired.

Uniform forms the certificate of conformity and declaration of conformity to technical regulation requirements of the Customs Union, and the rules of their filling, were approved by the ECE College Decision № 293 of December 25, 2012. One of the main requirements to the certificate or declaration, is that all fields of the form have to be filled, and is not permitted to make amendments (5 and 8 of the rules). These documents necessarily contain information about the applicant / the manufacturer of products consisting of the full name of the applicant / manufacturer, including the actual address (for the applicant additionally provides information of state registration, as well as telephone, fax, e-mail address).

If the manufacturer and the applicant can still make itself the appropriate changes in the operational documentation or on a plate with markings after notifying of the Certification Body, then according to paragraph 11 of the "Regulation on the registration of declarations conformity the product with requirements of TR CU" (app. the ECE College Decision № 76 from 04.09.2013) some making correctionsto the already registered declaration of conformity is not allowed. Thus, if necessary the applicant shall re-adopt a declaration of conformity and carry out its registration. For this purpose, it can be used by previous evidence base, actualized according to the period of limitation and requirements.

The situation is a little more complicated with the certificate, because the legislation does not provide any make corrections or re-issue the certificate (see point 8 Decision of the Board the ECE № 293 of December 25, 2012). The Certification body must again carry out the whole complex of works, ranging from registration of the application prior to the issuance of a new certificate after analysis of production conditions (if necessary) and product testing. In addition, after the change of address the organization must make changes to the corresponding registration documents, in which data must comply with the data specified in the manufacturer's agreement with the authorized person, contract, shipping documents, etc.

Might add that the customs services and other controlling authorities may classify mismatch of details about applicant / manufacturer as an administrative offense, so it is better to take care in advance and to issue the document for confirmation of conformity with the correct information.

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