CROSS-STANDARD public interest · Lithium battery / power bank
China-to-Armenia Lithium Battery & Power Bank Compliance Gap Matrix
AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of China lithium battery and power bank documentation against Armenia (EAEU / EAC) requirements: EAEU TR CU 004/2011 and 020/2011 conformity with the EAC mark on GOST IEC 62133 basis, TR EAEU 037/2016 hazardous-substance restriction, UN 38.3 transport, and the in-country importer obligation.
Dataset 2026-06-11
Last verified 2026-06-15
5 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Armenia (EAEU / EAC) | Gap / action | Source + verification date |
|---|---|---|---|---|
| EAEU Technical Regulation Framework and Hazardous-Substance Restriction (TR EAEU 037/2016) | China does not have a directly equivalent single regulation. Portable lithium battery packs for export are primarily subject to GB 31241-2022 (safety) and, for certain rechargeable battery product categories, mandatory CCC certification under the CNCA / SAMR catalogue. China's domestic hazardous-substance restriction is the China RoHS framework (GB/T 26572 limits and the SJ/T 11364 marking / Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products), which is structurally similar in scope to TR EAEU 037/2016 but is a separate Chinese domestic regime not recognised by EAEU bodies. There is no Chinese equivalent of the EAC conformity mark or EAEU certification / declaration procedure.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment (SAC/SAMR) GB/T 26572 — Requirements for concentration limits for certain restricted substances in electrical and electronic products (China RoHS) Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (MIIT, China RoHS) — domestic framework |
Armenia is a member of the Eurasian Economic Union (EAEU). Lithium batteries and power banks placed on the Armenian market are governed by the EAEU / Customs Union technical regulations rather than a standalone national battery law. The applicable acts include TR CU 004/2011 (safety of low-voltage equipment), TR CU 020/2011 (electromagnetic compatibility), and TR EAEU 037/2016 (restriction of the use of hazardous substances in electrical and electronic products — an EAEU RoHS-style restriction limiting lead, mercury, cadmium, hexavalent chromium, and certain brominated flame retardants). Conformity is demonstrated through certification or declaration via an accredited EAEU conformity-assessment body, after which the product bears the single EAC （ЕАС） conformity mark valid across all EAEU member states, including Armenia. SARM （国家标准化机构） maintains adopted GOST / GOST IEC standards used as the technical basis.TR CU 004/2011 — On the safety of low-voltage equipment (EAEU / Customs Union Technical Regulation) TR CU 020/2011 — Electromagnetic compatibility of technical equipment (EAEU / Customs Union Technical Regulation) TR EAEU 037/2016 — On restriction of the use of hazardous substances in electrical and electronic products (EAEU hazardous-substance restriction) |
The EAEU framework imposes obligations with no direct Chinese equivalent for exporters: (1) the single EAC conformity mark obtained through EAEU certification or declaration, not transferable from CCC; (2) the TR EAEU 037/2016 hazardous-substance restriction, which although similar in concept to China RoHS must be demonstrated under EAEU rules and documentation; (3) reliance on adopted GOST / GOST IEC standards as the technical basis rather than GB standards. Chinese exporters must engage an accredited EAEU conformity-assessment body and an in-country importer to obtain market access, regardless of existing GB 31241 or China RoHS compliance.[INFORMATIONAL] Market access to Armenia runs through the EAEU technical-regulation framework — TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 — evidenced by the single EAC conformity mark issued via an accredited EAEU body. Chinese GB 31241, China RoHS, and CCC do not by themselves satisfy these obligations. Exporters should prepare EAEU-facing conformity assessment on a GOST IEC basis and document hazardous-substance restriction compliance. | Eurasian Economic Commission (EEC) — Technical Regulations of the EAEU2026-06-15 · reference |
| Cell and Battery Pack Safety — GOST IEC 62133 under TR CU 004/2011 | China's primary safety standard for portable lithium battery packs is GB 31241-2022 (Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment), with GB 18287-2013 (mobile phone lithium-ion batteries) for specific products. GB 31241 is technically derived from IEC 62133-2 but contains national deviations in test severity and acceptance criteria. Testing by a Chinese CNAS-accredited laboratory to GB 31241 is NOT recognised by EAEU accredited bodies, because the EAEU conformity-assessment pathway requires testing against the adopted GOST IEC 62133 series by an EAEU-accredited laboratory.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment (SAC/SAMR) GB 18287-2013 — General specification for lithium-ion batteries for mobile phones (SAC) |
Portable lithium cells and battery packs placed on the Armenian (EAEU) market must meet the safety essential requirements of TR CU 004/2011 (safety of low-voltage equipment). The technical basis is the adopted GOST IEC 62133 series (GOST IEC 62133-2 for lithium systems), the EAEU national adoption of IEC 62133-2 covering abuse testing — overcharge, external short-circuit, crush, drop, thermal abuse, and forced discharge — and electrochemical performance limits. Conformity is demonstrated by testing at an accredited EAEU laboratory and issuance of a certificate or declaration of conformity, after which the EAC mark is affixed. A test report produced solely against the Chinese GB standard is not accepted under the EAEU conformity-assessment pathway.TR CU 004/2011 — On the safety of low-voltage equipment (EAEU / Customs Union Technical Regulation) GOST IEC 62133-2 — Secondary cells and batteries containing alkaline or other non-acid electrolytes — Safety requirements for portable sealed secondary lithium cells and batteries — Part 2: Lithium systems (EAEU adoption of IEC 62133-2) IEC 62133-2 — international base standard adopted as GOST IEC 62133-2 |
Although GB 31241 and GOST IEC 62133-2 share IEC 62133-2 as a common root, they are not mutually recognised. Key gaps for Chinese exporters to Armenia: (1) testing must be performed or accepted by an EAEU-accredited laboratory against the adopted GOST IEC 62133 series, not GB 31241; (2) the EAEU pathway issues a certificate or declaration of conformity and the EAC mark, with no Chinese counterpart document; (3) marking, labelling, and accompanying-documentation language requirements differ (Russian-language documentation is commonly required across the EAEU). An existing GB 31241 report may support engineering analysis but does not by itself establish EAEU conformity.[INFORMATIONAL] Armenian / EAEU market placement requires compliance with TR CU 004/2011, evidenced via an accredited-body certificate or declaration of conformity and the EAC mark, on a GOST IEC 62133-2 testing basis. Chinese GB 31241 certification does not by itself satisfy the EAEU conformity-assessment file, even though both trace to IEC 62133-2, so exporters should arrange EAEU-accepted testing and documentation. | Eurasian Economic Commission (EEC) — TR CU 004/2011 on safety of low-voltage equipment2026-06-15 · reference |
| EMC and EAC Conformity for Power Banks with Integrated Electronics — TR CU 020/2011 | China's domestic EMC requirements for electronic products are governed by GB/T 9254.1-2021 (radio disturbance characteristics of information technology equipment — Class B) for emissions and GB/T 17618-2015 (immunity characteristics of information technology equipment) for immunity. Products with wireless functions require SRRC (State Radio Regulation of China) type approval under MIIT administration, specific to Chinese radio frequencies and protocol implementations. Chinese GB/T EMC test reports and SRRC approval are NOT recognised under the EAEU TR CU 020/2011 conformity-assessment pathway or for EAEU radio-frequency authorisation.GB/T 9254.1-2021 — Information technology equipment — Radio disturbance characteristics — Part 1: Class B equipment (SAC/SAMR) GB/T 17618-2015 — Information technology equipment — Immunity characteristics — Limits and methods of measurement (SAC) SRRC type approval — State Radio Regulation of China, MIIT — required for products with wireless functions sold in China |
Power banks (portable battery packs with integrated charging circuitry, USB outputs, and display) are electronic apparatus subject to TR CU 020/2011 (electromagnetic compatibility) in addition to TR CU 004/2011 where in scope. Conformity is demonstrated against the adopted GOST CISPR / GOST IEC EMC standards by an accredited EAEU body and evidenced by the EAC mark. If the power bank incorporates wireless functionality (e.g., Qi wireless charging, Bluetooth state-of-charge indicator, NFC), additional radio-equipment approval applies — within Armenia and the EAEU this is handled through national radio-frequency authorisation and the relevant adopted radio standards, in addition to the EMC requirement. The conformity documentation must cover all applicable technical regulations under a single EAC declaration or certificate.TR CU 020/2011 — Electromagnetic compatibility of technical equipment (EAEU / Customs Union Technical Regulation) GOST CISPR 32 — Electromagnetic compatibility of multimedia equipment — Emission requirements (EAEU adoption) GOST CISPR 35 — Electromagnetic compatibility of multimedia equipment — Immunity requirements (EAEU adoption) National radio-frequency authorisation (Armenia / EAEU) — applicable where wireless functions are present |
Power banks with integrated electronics must demonstrate conformity with TR CU 020/2011 against the adopted GOST CISPR / GOST IEC EMC standards, evidenced by the EAC mark. Chinese GB/T 9254 and SRRC approvals may support engineering review but are not accepted as standalone evidence for an EAEU conformity file. For wireless variants: (1) the product must operate within EAEU / Armenian permitted frequency bands; (2) national radio-frequency authorisation is required in addition to EMC conformity; (3) the EAC declaration or certificate must cover all applicable technical regulations together. Many Chinese power banks designed for the domestic market may use channels or wireless protocols requiring re-characterisation for EAEU compliance, and documentation must typically be provided in Russian.[INFORMATIONAL] Power banks are electronic apparatus subject to EAEU TR CU 020/2011, with wireless variants additionally requiring national radio-frequency authorisation within Armenia / the EAEU. Conformity is demonstrated against adopted GOST CISPR / GOST IEC standards and evidenced by the EAC mark. Chinese GB/T 9254 reports and SRRC approvals are not standalone EAEU conformity evidence. The EAC declaration or certificate must cover TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 obligations together. | Eurasian Economic Commission (EEC) — TR CU 020/2011 on electromagnetic compatibility2026-06-15 · reference |
| Armenian / EAEU Market Access — EAC Mark, Certification / Declaration and In-Country Importer | China's domestic market access for lithium battery products uses a different framework: CCC (China Compulsory Certification, administered by CNCA / SAMR) is mandatory for certain rechargeable battery product categories sold domestically (e.g., mobile phone lithium batteries are CCC-listed). However, CCC certification is a Chinese domestic market requirement and is NOT recognised by the EAEU; it does not substitute for the EAC mark. Chinese manufacturers do not need to appoint an EAEU-resident importer / applicant for domestic Chinese sales, and there is no Chinese equivalent of the EAEU single-mark certification / declaration procedure or the in-country applicant obligation for exporters.CCC — China Compulsory Certification (CNCA/SAMR) — domestic China market access only; not recognised in EAEU GB 31241-2022 — domestic safety certification basis for portable lithium batteries |
Non-EAEU manufacturers placing portable lithium batteries or power banks on the Armenian market must fulfil the following market access obligations: (1) EAC conformity mark — affixed after completing the applicable conformity-assessment procedure (certification or declaration of conformity) under TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 through an accredited EAEU conformity-assessment body. (2) In-country importer / applicant — a person established within the EAEU (commonly the Armenian or other EAEU importer) must act as the applicant holding the certificate or declaration and bear responsibility for the product on the market; a foreign manufacturer cannot self-declare without an EAEU-resident applicant. (3) Accompanying documentation and marking — operational and safety documentation is commonly required in Russian, with marking in line with the EAC requirements. Armenia, being landlocked, is reached by rail and road, so consignment routing through the EAEU customs territory and the importer of record is integral to market entry.TR CU 004/2011 — On the safety of low-voltage equipment (EAC marking framework) TR CU 020/2011 — Electromagnetic compatibility of technical equipment (EAC marking framework) TR EAEU 037/2016 — On restriction of the use of hazardous substances in electrical and electronic products EAEU conformity-assessment rules — certification and declaration procedures and the single EAC （ЕАС） conformity mark |
Chinese manufacturers exporting portable batteries to Armenia face structural market access gaps with no Chinese domestic equivalent: (1) the EAC conformity mark obtained through EAEU certification or declaration — CCC is not transferable; (2) an EAEU-resident importer / applicant must hold the certificate or declaration and carry product responsibility before market placement; (3) accompanying documentation and marking obligations, commonly in Russian; (4) the conformity file must cover TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 together. As Armenia is landlocked, exporters must also plan rail / road routing through the EAEU customs territory. Total compliance cost may include accredited-body assessment fees, the EAEU importer / applicant arrangement, and translation / marking costs.[INFORMATIONAL] Chinese portable battery and power bank exporters must address EAEU market access obligations before Armenian market entry: the EAC conformity mark via certification or declaration under TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016, and an EAEU-resident importer / applicant holding the certificate or declaration. CCC certification does not transfer to or substitute for any of these EAEU requirements, and consignments must be routed by rail / road through the EAEU customs territory. | Eurasian Economic Commission (EEC) — Conformity assessment and the EAC mark2026-06-15 · reference |
| Transport Safety — UN 38.3 and ADR Class 9 (Lithium Batteries) | China requires UN 38.3 test reports for all lithium batteries transported by air, consistent with ICAO and CAAC (Civil Aviation Administration of China) requirements. For domestic road transport, GB 12268 (Dangerous Goods List) and JT/T 617 (Road Transport of Dangerous Goods) apply. For sea transport, the IMDG Code applies globally. Chinese exporters shipping lithium batteries by air already typically obtain UN 38.3 test reports; however, the specific ADR (road) and SMGS / RID (rail) classification and documentation requirements for carriage into and within the EAEU — driver / consignor training, vehicle and wagon marking, transport document format, and Russian-language documentation — are additional obligations not mirrored in Chinese domestic transport rules.GB 12268-2012 — List of dangerous goods (SAC/SAMR) — domestic road transport classification JT/T 617-2018 — Road transport of dangerous goods — requirements (Ministry of Transport, PRC) CAAC Order No. 55 — Provisions on the Transport of Dangerous Goods by Civil Aviation (CAAC) |
Lithium batteries (cells, battery packs, and power banks) are classified as dangerous goods for transport. All lithium batteries — regardless of origin — must have a valid UN 38.3 test report (UN Manual of Tests and Criteria, Part III, Section 38.3: Lithium Metal and Lithium-Ion Batteries) before transport. The UN 38.3 test covers altitude simulation, thermal test, vibration, shock, external short-circuit, impact / crush, overcharge, and forced discharge. As Armenia is landlocked, batteries typically arrive by road and rail: for road carriage into and within the EAEU, ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road) classifies lithium batteries as Class 9 (UN 3480 for cells / batteries, UN 3481 for batteries packed with or contained in equipment); for rail, the SMGS / RID dangerous-goods rules apply across the EAEU rail network; for any air leg, IATA DGR and ICAO Technical Instructions apply with state-of-charge limits for loose lithium-ion cells shipped as cargo.UN Manual of Tests and Criteria, Part III, Section 38.3 — Lithium Metal and Lithium-Ion Batteries (UN 38.3) ADR — European Agreement concerning the International Carriage of Dangerous Goods by Road, Class 9, UN 3480 / UN 3481 SMGS Annex 2 / RID — rail carriage of dangerous goods (EAEU rail network) IATA Dangerous Goods Regulations (DGR) and ICAO Technical Instructions (Doc 9284) — for any air leg |
UN 38.3 test reports are required globally and most Chinese exporters already hold them. The Armenia-specific gap is overland dangerous-goods compliance: for road, transport documents must conform to ADR Chapter 5.4, packages must carry UN 3480 / 3481 markings per ADR 5.2, and small-quantity limits per ADR 3.4 apply; for rail, SMGS / RID documentation and wagon marking apply across the EAEU network. Consignors must ensure receiving parties (the Armenian / EAEU importer and warehouses) hold appropriate dangerous-goods documentation, and accompanying paperwork is commonly required in Russian. Exporters should confirm their UN 38.3 reports are from an accredited laboratory and cover the specific cell / pack configuration being exported.[INFORMATIONAL] UN 38.3 testing is a universal transport requirement — Chinese exporters shipping lithium batteries to Armenia must hold valid UN 38.3 test reports from accredited laboratories. As Armenia is landlocked, the practical additions are ADR Class 9 documentation for road carriage and SMGS / RID for rail across the EAEU, with Russian-language paperwork. Most compliant Chinese exporters already meet UN 38.3; the gap is typically in overland dangerous-goods documentation and EAEU-side logistics compliance. | United Nations Economic Commission for Europe (UNECE) — ADR dangerous goods by road2026-06-15 · reference |
E-E-A-T
Named editorial review
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Official regulator, standards body, notified body, customs, or primary legal source preferred. Local PDFs are not accepted.
Editorial controlsRows must include publisher, official URL, access date, verification flag, and last_verified before human_reviewed can be true.
SOURCES
Official-source register.
- Eurasian Economic Commission (EEC) — Technical Regulations of the EAEU · accessed 2026-06-15 · reference · used in 1 rows
- Eurasian Economic Commission (EEC) — TR CU 004/2011 on safety of low-voltage equipment · accessed 2026-06-15 · reference · used in 1 rows
- Eurasian Economic Commission (EEC) — TR CU 020/2011 on electromagnetic compatibility · accessed 2026-06-15 · reference · used in 1 rows
- Eurasian Economic Commission (EEC) — Conformity assessment and the EAC mark · accessed 2026-06-15 · reference · used in 1 rows
- United Nations Economic Commission for Europe (UNECE) — ADR dangerous goods by road · accessed 2026-06-15 · reference · used in 1 rows