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Replacing the declaration on certification

The declaration of conformity and certificate of conformity shall have equal legal force in accordance with the Technical Regulations of the Customs Union "On the safety of machines and equipment" TR CU 010/2011.

TR CU 010/2011 contains a list of objects of technical regulation, which must conform with the technical regulations of the Customs Union "On the safety of machines and equipment" in the form of certification, as well as in the form of declaring.

It may seem from the outside that the procedure for declaring according to some schemes are much easier and less costly: the applicant forms the required complete set of documents, perform tests and registers the declaration. But he takes all responsibility, that its products comply with the requirements technical regulations.

At the same time, in accordance with paragraph 5 of Article 8 TR CU 010/2011 "...according decision to the applicant instead of declaring of conformity in respect of machinery and (or) equipment included in the list referred to in this technical regulations may be carried out a certification under schemes of certification equivalised schemes of declaring of conformity... "

Some manufacturers using this provision TR TC 010/2011 asking us to carry out the procedures for conformity assessment of their products to the requirements of the Technical Regulations in the form of certification, even though their products are to be declared.

Such applicants have various reasons.

One of them may be the absence or inadequacy at the applicant own evidence for conformity requirements of technical regulations. Not every manufacturer, for example, can carry out tests of their products. But even having such a desire is not always possible to test by the test laboratory because of the technological complexities of equipment installation.

As mentioned above, when declaring the applicant takes certain responsibility for the conformity of machines and (or) equipment with the requirements of technical regulations. In the case of certification of considerable responsibility is rested with the certification body that issued the certificate of conformity, test laboratory and its staff.

Another reason of refusal of declaring in favor of certification is a factor of a third party. After all an analysis of the documentation, testing by accredited testing laboratory, a qualifying the production by independent experts looks more solid. Because experts of certification body or specialists of testing laboratory do not depend on an applicant who has no right to have any pressure on them. Besides the view from the outside can identify weaknesses machines and equipment.

The requirement of the organizers of tenders, some customers of products may influence the decision whether or not to replace the declaring on the certification. In any case, this decision is made by the applicant, addressing to any certification body included in the Unified Register of certification bodies and testing laboratories (centers) of the Customs Union.

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