This is one of the questions we receive most often — from manufacturers, importers and customs brokers alike. A clear technical answer exists, but in practice it is not the most important factor. What determines whether a shipment of spare parts clears customs smoothly is the combination of two things: the customs practice in the destination country at that time, and the ability of the customs broker to justify the operation clearly and with the right documentation in hand.
An experienced broker with the correct paperwork can clear parts that are technically ambiguous. A broker without preparation can run into difficulties with parts that should be straightforward. The rules matter, but the preparation matters more.
The General Rule: The Joint Declaration Covers the Parts
As a general principle, spare parts do not need their own certification if the assembly to which they belong is covered by a valid EAC Declaration of Conformity. This is the concept of the joint declaration: when a system or assembly is certified under an EAC Declaration, its components are covered by that certification and do not require individual documentation.
The key condition is that the Declaration covering the assembly must be in force at the time of customs clearance. An expired or suspended Declaration does not provide coverage for the parts.
This principle is solid in theory. Its practical application at customs depends on three questions that must be answered before relying on it.
Question 1: Is the Quantity Consistent with Spare Part Use?
This question may seem obvious, and yet it is one of the most common sources of problems in practice.
Customs authorities assess whether the quantity being imported is reasonable for spare part or maintenance use. One unit, five units, ten units: consistent with after-sales service. Five hundred units or a thousand units of the same component: customs may interpret the shipment as independent production or commercial distribution, not maintenance supply.
When the quantity appears disproportionate to genuine spare part use, the argument that the parts are covered by the assembly’s Declaration weakens considerably. The broker will need a clear and credible explanation for the volume, and that explanation needs to be prepared before the shipment arrives at the border, not improvised at the point of clearance.
Question 2: Is the Part Subject to Stricter Conformity Requirements Than the Assembly?
This is the most technically complex of the three questions, and the one that most frequently causes real problems at customs.
The clearest example is electrical cables. Cables are subject to an EAC Certificate of Conformity — the more demanding of the two main EAC conformity documents. The assembly to which they belong — a machine, an electrical panel, an industrial system — is often covered only by an EAC Declaration of Conformity. When the component carries a higher level of conformity requirement than the assembly, customs may require the part to hold its own individual certification, regardless of the assembly’s Declaration.
Other components that can fall into this category include certain safety elements, high-voltage electrical components and pressure-bearing elements in specific industrial contexts.
This is the most difficult scenario for a customs broker. The joint declaration argument exists, and an experienced broker can present it — but it is the hardest position to defend when the part’s own conformity requirements are more stringent than those of the assembly it belongs to. The right course of action is to identify this situation before shipment and consult with the certification agent in advance.
Question 3: Are the Parts Subject to Mandatory Certification When Sold Independently?
The third question is the most actionable, and for many spare part shipments it is the one that leads to the most practical solution.
If the answer is no — if the component would not be subject to any mandatory EAC certification when sold as a standalone product — the most efficient approach is to obtain an Exemption Letter. This is a document issued by a certification body or an expert that confirms the product is not subject to mandatory conformity requirements under the applicable EAC Technical Regulations.
The cost of an Exemption Letter is low relative to the value it provides. It eliminates ambiguity at customs, reduces clearance time on repeat shipments, and gives the broker an official document that supports the import operation with no room for interpretation.
If the answer is yes — if the part would require its own EAC certification when sold independently — the joint declaration of the assembly remains the main argument, subject to the conditions in Questions 1 and 2 above.
A Practical Checklist Before Every Shipment
Before any spare part shipment, work through the following sequence:
1. Is the EAC Declaration of the assembly currently in force? If the Declaration has expired, been suspended or was never issued, the parts cannot rely on it for coverage. Certification for the parts will be required.
2. Is the quantity proportionate to spare part use? If the volume is high relative to what a maintenance or after-sales context would justify, prepare a written explanation of the commercial reason for the quantity before the shipment departs.
3. Does the part carry stricter conformity requirements than the assembly? If yes, consult with the certification agent before the shipment. This is the scenario where advance preparation has the highest impact on clearance outcome.
4. Would the part require mandatory EAC certification if sold independently? If no, obtain an Exemption Letter. The document is inexpensive, reusable for future shipments of the same part, and provides the broker with a clean and unambiguous justification at customs.
Conclusion
Spare parts do not always need their own EAC certification. The joint declaration principle provides a solid basis for many shipments. Smooth customs clearance is not automatic: it is the result of the broker having the right answers and the right documentation before the goods arrive at the border.
Get in touch with our team if you want to verify whether your current certifications cover your spare part shipments, or need guidance on whether an Exemption Letter is the right solution for your product.