If your company exports to both Europe and the Eurasian Economic Union, you’ve almost certainly come across both the CE and EAC marks. At first glance, they look similar: both are mandatory conformity marks, both grant access to a large trading bloc, and both require demonstrating that your product meets specific safety and technical requirements.
But that’s where the similarities end. CE and EAC are fully independent systems, governed by different regulatory frameworks, administered by different bodies, and valid in completely separate markets. Understanding how they work — and how they differ — is essential before you start selling across both regions.
What is CE Marking?
CE Marking is the mandatory conformity mark required to place products on the market of the European Economic Area (EEA), which includes all EU member states plus Iceland, Norway, and Liechtenstein.
The mark demonstrates that a product complies with the applicable EU Directives or Regulations — covering areas such as machinery safety, low voltage equipment, electromagnetic compatibility, pressure equipment, toys, and many others.
One important feature of the CE system is that foreign manufacturers can apply directly. A non-European company can self-declare conformity or appoint an EU-based authorised representative, without needing to work through an intermediary established in the EEA.
The key documents involved are the EU Declaration of Conformity and the technical file, which must be kept available for market surveillance authorities. Depending on the product’s risk level, conformity assessment may be handled through the manufacturer’s own self-declaration or through a third-party Notified Body.
What is EAC Marking?
EAC Marking (Eurasian Conformity) is the mandatory conformity mark for products placed on the market of the Eurasian Economic Union (EAEU), which comprises Russia, Kazakhstan, Belarus, Kyrgyzstan, and Armenia. Like CE, once a product is certified under the applicable EAEU Technical Regulations (known as CU TRs), it can be freely traded across all five member states without additional national certifications.
There are three main certification documents that authorise — and in fact oblige — the use of the EAC mark:
- EAC Declaration of Conformity — typically used for lower-risk products or specific certification schemes
- EAC Certificate of Conformity — required for higher-risk products, always involves third-party laboratory testing
- Certificate of State Registration — required for certain food-contact materials, chemical substances, and consumer goods with specific health-related requirements
One of the most significant structural differences from CE is who can apply. Under the EAC framework, only companies legally established in one of the five EAEU member states are eligible to act as applicant. Foreign exporters cannot apply directly — they must work through an EAEU-based entity, which can be their own local subsidiary, a local importer, or an independent professional applicant.
This distinction has real commercial consequences. The certified applicant is the only entity entitled to use the EAC document for customs clearance. If your importer holds the certification, they effectively control access to it — and other distributors cannot use it. For this reason, a growing number of exporters prefer to appoint an independent applicant, retaining full control over the certification and protecting their technical documentation and intellectual property.
CE vs EAC: Key Differences
| CE Marking | EAC Marking | |
|---|---|---|
| Market | EU / EEA | EAEU (Russia, Kazakhstan, Belarus, Kyrgyzstan, Armenia) |
| Who can apply | Manufacturer or EU-based representative | EAEU-based applicant only |
| Third-party testing | Only for higher-risk products | Always required for Certificates; may not be required for Declarations (scheme 1D) |
| Validity | No fixed expiry | 1–5 years |
| Language | English / local EU language | Russian |
| Mutual recognition | Not valid in the EAEU | Not valid in the EU |
Which Products Need Both Marks?
Many industrial products fall under both EU Directives and EAEU Technical Regulations, often because both systems are built on the same international standards. If you manufacture and sell any of the following in both markets, you will need both CE and EAC certification:
- Cables (Low Voltage Directive / CU TR 004 and 016)
- Industrial machinery (Machinery Directive / CU TR 010)
- Pressure equipment (PED / CU TR 032)
- Ex equipment (ATEX / CU TR 012)
- Lighting (Low Voltage + EMC / CU TR 004 and 020)
- Toys (Toys Safety Directive / CU TR 008)
- Fire safety equipment (various EU and EAEU regulations)
The good news is that in many of these sectors, the underlying technical requirements are closely aligned, and test reports produced for CE purposes may be reusable — at least in part — for EAC certification. More on this below.
Products Subject to CE but Not EAC
Not every product regulated in the EU has an equivalent CU TR in the EAEU. Some categories — such as certain medical devices, specific construction products, or particular electronic equipment — fall under EU Directives without a directly corresponding EAEU Technical Regulation.
However, the absence of a CU TR does not automatically mean your product can enter the EAEU freely. Depending on the specific product and destination country, customs authorities may still require:
- An Exemption Letter (also known as a Negative Decision), confirming that no CU TR applies
- A mandatory GOST R Certificate of Conformity or GOST R Declaration, which applies specifically to Russia outside the EAC framework
- Other national-level documents depending on the product category and destination
In short: always verify the regulatory status of your product before assuming it can enter the EAEU without certification.
Products Subject to EAC but Not CE
Perhaps the most surprising aspect of the EAC system for European exporters is how many everyday consumer products require EAC certification, even though they circulate freely in the EU with no mandatory conformity mark.
Products in this category include:
- Clothing and apparel (CU TR 007/017)
- Footwear (CU TR 006)
- Furniture (CU TR 025)
- Cosmetics and personal care products (CU TR 009)
- Wine and other alcoholic beverages (CU TR 021/029)
If your company exports any of these to Russia or other EAEU countries, EAC certification is mandatory — regardless of whether you have any CE obligations at home.
Can CE Test Reports Be Used for EAC Certification?
This is one of the most common questions from European exporters, and the answer is: it depends on the certification scheme.
As a general rule, CE and EAC are independent systems. A CE Declaration of Conformity carries no weight in the EAEU, and CE test reports are not automatically recognised by EAEU certification bodies.
However, there is an important practical exception. Under the EAC Declaration of Conformity — scheme 1D, conformity assessment is based on documentation provided by the manufacturer, which may include existing test reports, even those produced for CE purposes. The certification body reviews the documentation and, if the tests cover the relevant EAEU requirements, the existing reports can be used as the technical basis for the EAC Declaration — without the need for new laboratory testing.
This is a significant advantage for companies that already hold CE documentation for their products. In many industrial sectors, the 1D scheme can considerably reduce both the time and cost of obtaining EAC certification.
How to Get Started
If you are planning to export to the EAEU for the first time — or if you already have certifications that may need updating — here are the key steps:
- Identify which CU TRs apply to your product. Some products fall under a single regulation; others may be subject to several simultaneously.
- Determine the appropriate certification document — Declaration, Certificate, or Certificate of State Registration — and which scheme applies.
- Choose your applicant carefully. This decision has long-term commercial implications and should not be taken lightly.
- Assess whether existing CE documentation can be reused, particularly if the 1D scheme applies to your product.
- Work with a specialist who can manage the process end to end, from technical documentation to customs clearance.
At GOST Standard, we offer a free certificates review for companies that already hold EAC or GOST certifications and want to check their validity or plan ahead. Get in touch to find out how we can help.
Conclusion
CE and EAC Marking follow the same underlying logic — demonstrate conformity, apply the mark, access the market — but they operate in entirely separate regulatory universes. They serve different regions, involve different procedures, require different applicants, and cannot substitute each other.
For exporters selling in both the EU and the EAEU, the key is to plan both certifications together wherever possible. Understanding which products need one mark, the other, or both — and knowing when existing CE documentation can be leveraged for EAC purposes — can make a significant difference in terms of time, cost, and market readiness.