EAEU Battery and Hazardous-Substance Conformity — TR EAEU 037/2016 and TR CU Basis?

Chinese GB 31241 or CCC documentation is useful technical input but does not complete Kazakhstan EAEU route obligations. Exporters should map CN evidence into the TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 framework before shipment.

Cell and Pack Safety — TR CU Basis and GOST IEC 62133?

Use GB 31241 and CN safety reports as supporting material, then close documentation gaps against the EAEU TR CU 004/2011 route and ST RK/GOST adoption basis before shipment to Kazakhstan.

EMC and EAC Marking for Portable Battery Products?

Kazakhstan EAC market entry generally needs TR CU 020/2011 EMC confirmation for in-scope products, and wireless variants require the applicable telecom acceptance pathway. Chinese GB and SRRC records are not standalone replacement evidence.

Kazakhstan Market Access — EAC Marking, Importer Role, and Local Filing?

Kazakhstan market access is commonly structured around local importer-managed filing and EAC evidence. CN safety data supports engineering review but is not the same as completing EAEU import market obligations.

Lithium Battery Transport — UN 38.3, ADR Rail/Road Corridor, and Kazakhstan Import Routing?

UN 38.3 remains mandatory across transport modes, and Kazakhstan-bound rail/road flows add documentation discipline risks at each transfer point. CN reports are valuable but do not remove the requirement for route-specific ADR and consignee-side transport alignment.

China-to-Kazakhstan Lithium Battery and Power Bank Compliance Gap Matrix

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item	Common China baseline	Kazakhstan (EAEU / EAC)	Gap / action	Source + verification date
EAEU Battery and Hazardous-Substance Conformity — TR EAEU 037/2016 and TR CU Basis	China export documentation typically starts from GB 31241-2022 safety and CCC where applicable. These instruments are domestic market tools and do not substitute Kazakhstan EAC conformity steps. CN documentation may support technical comparison, but Kazakhstan requires the EAEU route, EAC evidence, and importer-handled market access steps before placement.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries CCC — China Compulsory Certification for selected domestic product categories	Kazakhstan applies EAEU technical regulation routes for in-scope electrical and battery products with mandatory EAC marking. The key legal anchors are TR CU 004/2011 on low-voltage safety, TR CU 020/2011 on electromagnetic compatibility, and TR EAEU 037/2016 on restricted substances in electrical and electronic equipment and batteries. Importantly, Kazakhstan is within the EAEU, so energy-efficiency and import procedures are handled in the EAC technical framework and by in-country importer arrangements, not through separate China-export-only pathways.TR CU 004/2011 On the safety of low-voltage equipment TR CU 020/2011 Electromagnetic compatibility of technical devices TR EAEU 037/2016 Restriction of hazardous substances in electrical and electronic equipment EAEU conformity assessment and EAC marking rules	The structural gap is procedural and documentary. A Chinese GB 31241 report or CCC file does not by itself create Kazakhstan market access. Kazakhstan expects EAEU TR CU based evidence, EAC marking workflow through qualified channels, and in-country importer responsibility for customs and local filings.[INFORMATIONAL] Chinese GB 31241 or CCC documentation is useful technical input but does not complete Kazakhstan EAEU route obligations. Exporters should map CN evidence into the TR CU 004/2011, TR CU 020/2011, and TR EAEU 037/2016 framework before shipment.	Eurasian Economic Commission2026-06-15 · reference
Cell and Pack Safety — TR CU Basis and GOST IEC 62133	China baseline remains GB 31241-2022 and related domestic battery standards as technical starting points. These are used for Chinese domestic compliance and export quality management, but they are not the same compliance proof as the Kazakhstan EAEU technical-file route.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries GB 18287-2013 — General specification for lithium-ion batteries	Lithium cells, battery packs, and power banks placed in Kazakhstan must align to Kazakhstan market safety expectations through the EAEU TR CU mechanism. In practice this is implemented by conformity bodies using GOST and ST RK-adopted references, including GOST IEC 62133-based safety expectations for portable lithium packs, plus type-circuit and protective testing consistent with the EAEU scope. Final configuration, chemistry, protection design, and intended use determine whether the route is declaration or certification.TR CU 004/2011 — Low-voltage equipment safety requirements GOST IEC 62133 basis for lithium cells and battery packs, where adopted through ST RK alignment EAEU conformity assessment rules for TR CU scope products	The gap is usually in pathway recognition and documentation depth. A CN test report is useful, but it must be mapped to EAEU TR CU scope clauses for final in-country model variants. Differences commonly appear in failure criteria, abuse testing assumptions, and required declarations for importers and distributors.[INFORMATIONAL] Use GB 31241 and CN safety reports as supporting material, then close documentation gaps against the EAEU TR CU 004/2011 route and ST RK/GOST adoption basis before shipment to Kazakhstan.	International Electrotechnical Commission (IEC)2026-06-15 · reference
EMC and EAC Marking for Portable Battery Products	Chinese EMC and radio testing for GB/T series products is useful for engineering but is not equivalent proof of EAEU EMC filing for Kazakhstan. Domestic SRRC or MIIT approvals are separate from EAEU TR CU 020/2011 obligations.GB/T 9254 series — EMC emission requirements for information technology equipment GB/T 17626 series — Immunity requirements SRRC/MITT approvals for domestic Chinese radio use	Power banks with integrated electronics in Kazakhstan are subject to EMC conformity review under EAEU TR CU 020/2011 through EAC technical-file logic. Products with radio, wireless charging, or communication functions additionally require the relevant EAEU technical requirements and telecom-type acceptance before market placement. Conformity evidence, marking language, and declarations must match the exact shipped configuration.TR CU 020/2011 On electromagnetic compatibility of technical devices EAEU conformity route for EMC under EAC marking framework Applicable EAEU telecom equipment acceptance rules where wireless functions are integrated	The common gap is not test type but acceptance scope. CN lab reports often lack EAEU-referenced clause mapping for final SKU, mode settings, wireless channels, or in-country installation context. Exporters should map the report matrix to TR CU 020/2011 and retest where configuration-sensitive variants differ.[INFORMATIONAL] Kazakhstan EAC market entry generally needs TR CU 020/2011 EMC confirmation for in-scope products, and wireless variants require the applicable telecom acceptance pathway. Chinese GB and SRRC records are not standalone replacement evidence.	Eurasian Economic Commission2026-06-15 · reference
Kazakhstan Market Access — EAC Marking, Importer Role, and Local Filing	China uses domestic GB and CCC pathways for local market entry and has no direct in-country importer role for Kazakhstan customs law. CN certificates help evidence product quality domestically but are not substitutes for EAC-conformity file ownership and importer obligations in Kazakhstan.GB 31241-2022 and related domestic lithium product controls CCC mandatory catalogue system managed domestically in China	Because Kazakhstan is in the EAEU, lithium battery and power bank shipments are assessed through EAC technical-file procedures. The importer in Kazakhstan normally interfaces with customs, filing, and market oversight steps. In practice this means EAC conformity evidence, correct marking language, declarations, and energy-efficiency related documentation for the in-scope components must be prepared with local implementation details.TR CU and TR EAEU conformity framework for in-scope products EAC technical-file and marking rules Kazakhstan customs and market-entry filing requirements in EAEU trade context	The practical gap is operational. Chinese exporters often assume a technical report can directly pass market access. In Kazakhstan, the import side usually needs EAC-ready paperwork aligned with local language and importer declarations. If no qualified importer process is established, customs and post-clearance review risks increase.[INFORMATIONAL] Kazakhstan market access is commonly structured around local importer-managed filing and EAC evidence. CN safety data supports engineering review but is not the same as completing EAEU import market obligations.	Eurasian Economic Commission2026-06-15 · reference
Lithium Battery Transport — UN 38.3, ADR Rail/Road Corridor, and Kazakhstan Import Routing	China already applies UN 38.3 and dangerous-goods documentation in many export scenarios. Those are still needed for Kazakhstan shipments, but they must be aligned to Kazakhstan routing, road leg declarations, and consignee-side interpretation. Mismatches in charge state, unit configuration, or package marks can block transport clearances.UN 38.3 test report and test summary China dangerous-goods transport documentation for lithium batteries Air and road carrier documentary rules where used	Lithium batteries and power banks exported from China to Kazakhstan require valid UN 38.3 test basis for dangerous-goods transport. Kazakhstan logistics is generally landlocked with rail and road movements, and shipments should match correct UN numbers, packing group limits, marking, and multimodal documentation from consignee to transport mode in each leg. Air shipments should additionally align with IATA and ICAO dangerous-goods requirements for state-of-charge and sectioning.UN Manual of Tests and Criteria, Part III, 38.3 — Lithium batteries ADR 2023 Class 9 dangerous goods transport provisions for road transport IATA Dangerous Goods Regulations — air transport requirements ICAO Technical Instructions for the safe transport of dangerous goods by air	The gap is usually one of route-specific evidence quality rather than legal absence. CN documentation for one configuration may not cover the exact Kazakhstan rail/road lot design, unit state of charge policy, or consignee transport declarations. Import and logistics teams should validate each shipment against UN 38.3 scope, ADR-compatible labeling, and local carrier document acceptance.[INFORMATIONAL] UN 38.3 remains mandatory across transport modes, and Kazakhstan-bound rail/road flows add documentation discipline risks at each transfer point. CN reports are valuable but do not remove the requirement for route-specific ADR and consignee-side transport alignment.	United Nations Economic Commission for Europe (UNECE)2026-06-15 · reference

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