What documents are needed to import a machine into the EAEU?

An importer's file must be assembled before the machine is shipped, not after the container arrives. By then, four descriptions of the same product must match: contractual, technical, classification, and certification descriptions. If even one of them shows a different model, function, configuration, or manufacturer, customs and the conformity assessment body will see different products.

I have repeatedly seen shipments where the equipment was already in port and only then did the importer ask the factory to send a Russian-language manual and explain whether a turning-milling center was a lathe or a machining center. In that situation, the carrier sets the timeline, the seller responds slowly, and every correction turns into downtime. The proper order is the reverse: first identify the product and determine the conformity assessment route, then conclude the contract and ship it.

First, establish exactly what you are importing

An importer needs more than a general manufacturer catalogue. They need an unambiguous description of the specific machine and the delivery scope. The name “CNC machine” is almost useless for customs classification and conformity assessment. It does not say which operation the machine performs, how many spindles it has, where its axis of rotation is located, whether it can mill, or whether it arrives as a finished product.

Record the manufacturer, trade name, model, version, serial number if available, year of manufacture, intended use, and main operations. Describe the configuration separately: bed, spindle unit, turret, CNC system, control cabinet, chip conveyor, hydraulic unit, cooling system, bar feeder, robot, guards, and accessories.

The delivery boundary has legal significance. One fully equipped turning center and a set of separate machines for an automated line may have different codes, documents, and identification methods. The same applies to a disassembled machine, an incomplete machine, and standalone components. The invoice wording “CNC line, 1 set” does not prove that the goods are one functional unit.

Verify the information against at least four sources: the nameplate, technical passport, commercial offer, and configuration drawing. Request a photo of the nameplate before shipment. If the machine has not yet been made, agree on a nameplate layout and the serial-number assignment rule.

At this stage, also determine whether the machine is new or used. Year of manufacture and condition are not interchangeable. A machine may have been stored for several years without use, while a recently refurbished machine may have an old nameplate and a new control system. These factors are assessed separately when determining the applicability of regulations and evidence requirements.

The contract must describe the same product that will be shipped

The contract and specification must make it possible to link the payment, shipment, and conformity document to one machine. If the contract says “lathe,” the declaration says “multi-purpose turning center,” and the nameplate bears a different model designation, the importer will have to prove identity after a question arises.

In the specification, state the full name, manufacturer, model, quantity, condition, country of origin, and delivery contents. For a single machine, add the serial number if it has already been assigned. If the delivery comes in several transport lots, list the packages and units so the documents show that these are parts of one machine, rather than separate products with no defined purpose.

The price also needs a breakdown. Separate the cost of the machine from tooling, spare parts, consumables, software, installation, training, transport, and insurance. The breakdown must not be artificial, but it helps determine customs value correctly and prevents independent products from being assigned the main machine's code without analysis.

It is best to set out the seller's document obligations directly in the contract. State the deadline for providing the technical description, manual, passport, electrical and hydraulic diagrams, safety justification, test reports, and manufacturer information. Include an obligation to correct discrepancies between the nameplate, packing documents, and technical documentation before shipment.

Agree on EAC marking separately. The manufacturer must not apply it in advance merely because the delivery is going to Kazakhstan. The mark is applied after all required conformity assessment procedures are complete and before the product is placed on the market. The contract can require the factory to apply an approved layout after receiving the details of the registered document, or provide access for marking before the goods are placed on the market.

A typical failure looks like this. The buyer orders “vertical center model V850,” the factory changes the CNC system and model suffix to V850B, but the manager does not update the specification. The laboratory tests V850B, the declaration is prepared for V850, and the invoice repeats the old name. This is not a typo in one document, but three different identifications. The primary documents and the declaration scope must be corrected, rather than sending a letter saying the letter B means nothing.

Do not select an HS code from the name alone

The EAEU HS code is determined by the product's function, design, and degree of completeness, not by the code in the seller's export declaration. In its classification guidance, the Eurasian Economic Commission expressly lists intended use, performed function, design, technology, and processing stage as criteria. Customs Union Commission Decision No. 522 requires the General Rules for the Interpretation to be applied in sequence.

For machine tools, headings 8457, 8458, and 8459 are often considered. Machining centers, unit construction machines, and certain multi-operation machines fall under heading 8457. Metalworking lathes, including multi-purpose turning machines, are considered under heading 8458. Drilling, boring, milling, and thread-cutting machines that are not lathes fall under heading 8459. These are guideposts, not ready-made codes.

A ten-digit code requires answers to narrower questions. Is the machine horizontal or vertical? Does it have CNC? Is it an automatic lathe? How many spindles does it have? Does it change tools by program? Can it perform different operations in sequence without manually repositioning the workpiece? What is the principal function of a combined machine?

The classification description and the conformity assessment description solve different tasks. The first explains why the product belongs in a specific HS heading. The second proves that the machine meets safety requirements and matches the object in the declaration. The fields overlap, but one document does not replace the other.

Obtain from the manufacturer a general arrangement drawing, a list of operations, axis layout, and information on spindles, tooling system, and automatic tool changing. For a line, add a workpiece-flow diagram and describe each machine's role. Provide this package to the customs representative for a written opinion. A request to “select a code from a photograph” may save an hour before the deal and cost weeks after arrival.

If classification affects the duty rate, prohibitions, a benefit, or the form of conformity assessment and remains debatable, consider a preliminary customs decision. It requires a full technical description, but provides a position before the goods declaration is filed.

The code and technical regulation answer different questions

A single HS code does not automatically determine the full set of technical regulations. The code helps locate a product in the lists, but a regulation's scope is determined by the product's intended use and characteristics. The mistake occurs when an importer finds a code in a table and stops reading the regulation itself.

For a new metalworking machine, the main regulation is usually TR CU 010/2011 “On the Safety of Machinery and Equipment.” In the current system, metalworking machines are generally assessed by declaration because they are included in the relevant part of Annex No. 3. The specific model must still be checked against the current version of the list and the object description.

The presence of an electrical cabinet does not mean TR CU 004/2011 is automatically added to the machine. Following the 2022 amendments, the scope of that regulation excludes low-voltage equipment that falls under TR CU 010/2011 and is assessed under it, apart from certain specified products. Mechanically adding “004” to every declaration for electrical machines shows that no one has analysed the regulations' scope.

TR CU 020/2011 “Electromagnetic Compatibility of Technical Devices” is checked separately. Control systems, converters, servo drives, and communication equipment can create interference and be affected by it. At the same time, the regulation ceases to apply to product types whose electromagnetic compatibility requirements have already been established by another applicable technical regulation. The conclusion must be based on the design of the specific machine, not the habit of a body or broker.

Additional regulations may arise because of equipment operating under excess pressure, use in an explosive environment, gas equipment, or other independent functions. A small receiver inside a machine does not provide a ready answer: assess the parameters, intended use, exclusions, and whether the unit is supplied as part of the machine or as a separate product.

EEC Council Decision No. 36 of 13 March 2026 amends TR CU 010/2011 from 1 September 2026, while some provisions apply later. For deliveries undergoing assessment around the transition date, compare the registration date of the document, transition provisions, and the new version of the lists. An old declaration template or last year's opinion on a similar machine does not replace this check.

The technical description must answer questions without further correspondence with the factory

A good technical description allows the machine to be classified, identified, and assessed without asking the seller ten more questions. A catalogue page with a photo and travel range is too sparse for this.

Prepare a separate model card. You can send it to the manufacturer as a form to complete:

Manufacturer and production-site address:
Trade name:
Model and version:
Serial number and year of manufacture:
New or used:
Intended use and materials processed:
Operations performed:
Configuration type and number of controlled axes:
Number and position of spindles:
Automatic tool changing available:
CNC system and electric drive configuration:
Voltage, frequency, installed power:
Dimensions and weight:
Standard delivery contents:
Options, spare parts, and separate accessories:
Supplied assembled or disassembled:
List of accompanying drawings and diagrams:

Do not copy specifications from the seller's offer without checking them. Main-motor power, machine installed power, and total line power consumption are different values. The number of controlled axes is also not the same as the number of axes capable of simultaneous interpolation. For classification and safety assessment, this difference can sometimes change the conclusion.

Attach a general arrangement drawing identifying the main units, a work-area diagram, and a list of safety guards and interlocks. An automated line needs a layout plan, control boundaries, workpiece-transfer points, and an emergency-stop description. If the robot is supplied by another manufacturer, the documents must show who assessed the risk of their joint operation.

The information in the model card must be repeated in the passport, manual, test application, report, and declaration without unauthorized abbreviations. Model transliteration is acceptable, but an importer's internal part number must not be turned into the manufacturer's model.

An operating manual is not a marketing brochure

Operating documents must describe the safe use of the specific machine throughout its life cycle. TR CU 010/2011 requires information on design, operating principle, characteristics, installation, setup, maintenance, repair, and safety measures. A catalogue with a parameter table does not meet these requirements.

The minimum practical package for a machine usually includes:

• an operating manual in Russian;
• a machine passport with identification details;
• electrical, hydraulic, and pneumatic diagrams;
• a foundation plan, lifting points, and connection requirements;
• a maintenance schedule and list of wear parts.

The manual must explain operator qualifications, intended use, reasonably foreseeable misuse, residual risks, protective measures, emergency-stop procedure, and safe chip removal. The setup technician needs energy-isolation procedures before entering a hazardous area. The phrase “use caution” does not replace a sequence for disconnecting electrical, hydraulic, and pneumatic energy.

Prepare the translation from the source document that applies to the supplied version. If the manufacturer updated the guard door, drive, or software function, an old manual may describe a different interlock. Request the document revision number and link it to the machine model.

Do not have terms translated by someone who has never seen the machine. Errors in axis directions, clamping commands, and pressure warnings are more dangerous than stylistic flaws. A technical translation should be reviewed by an engineer, and labels on the panel, diagrams, and manual must match.

For sale in Kazakhstan, check requirements for the state language and the content of user information in advance. TR CU 010/2011 requires Russian and refers to the legislation of the country of sale regarding the state language. It is too late to address this during commissioning: plates, warnings, and documents should already be coordinated.

Evidence must relate to the supplied model

An evidence package is not needed to make a larger file. It is needed to connect safety requirements with technical solutions and verification results. Article 8 of TR CU 010/2011 lists safety justification, operating documents, applied standards, a contract for a batch or single item, research information, test reports, and documents on materials and components.

The safety justification must describe hazards and the measures the manufacturer took to reduce risk. For a turning center, this includes at least access to rotating parts, ejection of a workpiece or tool, chuck failure, chips and cutting fluid, electrical hazards, noise, fire, setup errors, and stored energy. A hazard list without a link to guards, interlocks, and operating modes proves very little.

Collect evidence in four groups:

• design documentation and safety justification;
• a list of applied standards with their editions;
• test and measurement reports identifying the sample;
• certificates and reports for safety-related components;
• production and management-system documents, if required by the scheme.

A report must make it clear what was tested. Check the manufacturer, model, sample serial number, photographs, dates, methods, and measured values. A report for “CNC machine series V” with no model list may not cover the supplied V850B. A report whose photos show a different cabinet and guard configuration is even worse.

Foreign certificates, CE declarations, and reports under ISO or IEC standards can be useful source evidence. They do not replace an EAEU declaration or certificate. First compare requirements and methods, then decide whether the material can be used in the selected scheme.

Do not accept advice to issue a declaration using only your own evidence if the applicant lacks a technical file and the competence to assess it. This route is popular because it promises a lower price. In a declaration procedure, the applicant bears responsibility, and an empty safety justification and unsuitable factory report remain with that applicant.

Choose the applicant and scheme before ordering tests

The applicant must be entitled to accept the declaration and bear responsibility for product conformity. A foreign factory outside the EAEU cannot simply name itself as the applicant. An organization or individual entrepreneur registered in a Union state and meeting the requirements of the selected regulation and scheme is needed.

For serial production, the applicant is usually an EAEU manufacturer or a person authorized by the manufacturer. Authority is formalized by an agreement providing for compliance of the supplied products with regulatory requirements and responsibility for non-conformity. A simple letter saying “we authorize representation of our interests” is a weak basis for this role.

For a batch or single item, the applicant may be the importer if the scheme and regulation allow it. In that case, the declaration must identify the limited supply through the contract, invoice, quantity, and, where necessary, serial numbers. You cannot issue a document for one machine and use it for the next merely because the model matches.

Prepare the applicant's registration information: full name, legal address, operating address if different, registration or identification number, telephone number, email address, and details of the director or authorized signatory. In Kazakhstan, check the spelling of the BIN, address, and name against registration records. One extra letter rarely changes machine safety, but it disrupts automated checks of registers and customs information.

The applicant and the import declarant may be different persons only where there is a legal basis to use the document. EEC Council Decision No. 130 permits confirmation through a document in which the declarant is named as the applicant, or through authority provided for serial products. This arrangement must be agreed before filing the goods declaration.

Test samples are imported under a separate basis

The lack of a completed declaration does not always block a sample import, but the purpose and quantity must be documented in advance. EEC Council Decision No. 130 provides an exemption for samples imported for research, testing, and measurement. The declarant must have a contract with the relevant conformity assessment body or its letter confirming the required number of samples.

Do not call an entire commercial batch a sample. The body or laboratory must substantiate the quantity needed for the procedure. For a large machine, the sample may be the unit itself, but this does not remove the need for a documented route, customs-procedure conditions, and subsequent actions after testing.

Before dispatch, agree with the body on the model, scheme, applicable regulations, standards, test location, and sampling procedure. Testing an installed machine at the buyer's site is possible only when the selected scheme, laboratory competence, and sampling procedure allow it. A middleman's promise that “an engineer will inspect it after start-up” is not a test program.

For importing a sample, include the body's contract or letter, application, technical description, supply contract, invoice, packing list, and declarant notification in the prescribed form. Details in all documents must identify the same sample. After the assessment is complete, formalize the result and only then address release onto the market and marking.

A separate exemption is provided for a single item that the declarant uses solely for its own needs, without sale, transfer, or other distribution. In practice, this condition is interpreted too broadly. Decision No. 130 regulates confirmation of technical-regulation measures at import, but it does not automatically cancel the requirements of the technical regulation itself, industrial safety, or safe operation. Before using the exemption, obtain a written conclusion for the specific transaction and intended use of the machine.

The customs file must match the technical file

Customs does not request the whole engineering archive for every shipment, but it compares the information in the goods declaration with commercial and authorization documents. The conformity document or its details must be held by the declarant when the goods declaration is filed if the selected procedure requires confirmation of technical-regulation measures. Under Decision No. 130, the document must be valid on the specified verification date.

Prepare the contract with specifications and amendments, commercial invoice, packing list, and transport documents. Depending on the transaction, payment documents, transport and insurance information, and documents confirming customs value and origin may be needed. A certificate of origin is not universally required for every machine, but without it you cannot claim an applicable tariff preference.

For heavy equipment, the packing list must show the number of packages, gross and net weight, dimensions, package markings, and the contents of each crate. If the machine is disassembled for transport, list the main units. A customs inspector should not have to guess why the electrical cabinet, conveyor, and bed belong to one machine.

Before filing, check the declaration or certificate record in the unified register. Compare the status, validity period, applicant, manufacturer, site address, model, HS code, applied regulations, scheme, and evidence. A PDF sent by an intermediary guarantees nothing if the record is missing, suspended, or relates to another factory.

After conformity is confirmed, marking on the machine and in the documents must match the registered details. Do not apply EAC automatically to spare parts and accessories together with the main machine. Each independent product may have its own assessment route.

Authorize shipment only after a final cross-check

The final check must be completed before paying the balance and handing the cargo to the carrier. I use five control gates:

1. Commercial documents name one manufacturer, one model, and the agreed configuration.
2. The technical card supports the ten-digit HS code and the scope of applicable regulations.
3. Operating documents relate to the supplied version and are ready in the required languages.
4. The applicant, scheme, samples, and evidence are agreed with a competent body or laboratory.
5. The conformity document is registered, or a lawful basis is documented for importing a sample or using another exemption.

Assign an owner to each line and retain dated document versions. A file named manual_final.pdf is almost guaranteed to stop being final. Use names such as V850B_manual_RU_rev03_2026-07-15.pdf, and keep the source file and signed version of reports separately.

The check is best performed jointly by an engineer, a conformity specialist, and a customs representative. The engineer sees incorrect power data and a missing interlock. The conformity specialist notices an unsuitable scheme. The customs representative checks the code, value, and accompanying-document package. It is wrong to place all responsibility on one broker: the broker did not design the machine and does not accept the declaration on the applicant's behalf.

For EAST CNC deliveries, it makes sense to begin this cross-check while selecting the model, since the company supports consultation, delivery, commissioning, and service. However, the applicant's signature still means their own responsibility, so the technical file must remain with the importer, not only with the intermediary.

Do not release the machine with the words “we will catch up with the paperwork on the way.” Once the container is loaded, the manufacturer has gained the main argument in negotiations: the equipment has physically left. Before shipment, the importer should be able to open one file and show within minutes what is stated in the contract, how the product is classified, which requirements it meets, and what proves this.