CROSS-STANDARD public interest · PPE / respirator (mask)
China-to-Kazakhstan PPE Respirator (FFP Mask) 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 Chinese PPE respirator (KN95 / GB 2626) documentation against Kazakhstan requirements under the EAEU technical regulation TR CU 019/2011 (On the safety of personal protective equipment), mandatory EAC certification by an EAEU-accredited conformity assessment body, GOST EN 149-type harmonised standards for filtering facepiece respirators, EAC marking, Russian/Kazakh-language labelling obligations, and the applicability of TR EAEU 037/2016 (RoHS-style restriction of hazardous substances) to electrical PPE components.
Dataset 2026-06-11
Last verified 2026-06-16
6 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Kazakhstan (EAEU/TR CU) | Gap / action | Source + verification date |
|---|---|---|---|---|
| Conformity Assessment — EAC Certification under TR CU 019/2011 (PPE, certification category) | For industrial respiratory protection in China, GB 2626-2019 (KN95) applies with compulsory CCC certification administered by CNCA and third-party certification bodies such as CQC. The conformity assessment involves type testing by a CNAS-accredited laboratory and factory inspection. Chinese CCC certificates and GB 2626 test reports are not recognised by EAEU member states as equivalent to an EAC certificate under TR CU 019/2011. A separate EAC certification process via an EAEU-accredited body is required.GB 2626-2019 — Respiratory protective equipment — Non-powered air-purifying particle respirator (CCC mandatory certification under CNCA) GB 19083-2010 — Technical requirements for medical protective mask (NMPA Class II medical device registration) |
Respiratory PPE exported to Kazakhstan (an EAEU full member) must comply with EAEU Technical Regulation TR CU 019/2011 「On the safety of personal protective equipment」. Filtering facepiece respirators fall in the certification (not declaration) conformity assessment category under this TR. This means the manufacturer must engage an EAEU-accredited conformity assessment body (certification body) to perform type testing against applicable GOST harmonised standards (notably GOST EN 149, equivalent to EN 149 FFP test methods) and issue an EAC certificate of conformity. Self-declaration (declaration of conformity) is not permitted for respiratory PPE under TR CU 019/2011. The EAC certificate must be obtained before the product is placed on the Kazakhstan market.TR CU 019/2011 — EAEU Technical Regulation 「On the safety of personal protective equipment」 (Decision of the Customs Union Commission No. 878, 9 December 2011) GOST EN 149-2003 (harmonised with EN 149:2001) — Respiratory protective devices — filtering half masks for protection against particles |
The entire conformity assessment must be re-run with an EAEU-accredited certification body. Key gaps: (1) Chinese CCC certificates and GB 2626/NMPA documentation do not satisfy TR CU 019/2011 EAC certification requirements; (2) An EAEU-listed accredited certification body must perform type testing to GOST EN 149 (or equivalent harmonised standard) and issue an EAC certificate of conformity; (3) Respiratory PPE is a certification category — self-declaration (declaration of conformity) is prohibited; (4) The EAC certificate must be obtained before EAC marking is applied and before market placement in Kazakhstan or any EAEU member state; (5) Factory audits by the accredited body may be required as part of ongoing production surveillance.[INFORMATIONAL] Respiratory PPE (filtering facepiece respirators) falls in the EAC certification category under TR CU 019/2011. Chinese CCC or GB 2626 test reports do not satisfy this requirement. Exporters must engage an EAEU-accredited certification body to obtain an EAC certificate before placing products on the Kazakhstan market. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
| Labelling — Russian/Kazakh language, TR CU 005/2011 and TR CU 019/2011 requirements | Chinese GB 2626-2019 and related standards require Chinese-language labelling on the product and packaging, including product name, standard reference (GB 2626), filtration class (KN95 etc.), manufacturer name, production date, and shelf life. User instructions must be in Chinese. Chinese-language labelling does not satisfy EAEU Russian-language labelling requirements; full Russian (and optionally Kazakh) relabelling of product, packaging, and user instructions is required before export to Kazakhstan.GB 2626-2019 — Respiratory protective equipment — labelling clauses (Clause 8) GB/T 191 — Packaging — Pictorial marking for handling of goods |
PPE products (including respiratory PPE / filtering facepiece respirators) placed on the Kazakhstan market must bear labelling in Russian, with Kazakh also permitted or required by national regulation. Labelling requirements derive from two interlocking EAEU technical regulations: (1) TR CU 019/2011 — specifies PPE-specific labelling elements including product designation, protection class/level, manufacturer name and address, date of manufacture, service life, and applicable standard or TR reference; (2) TR CU 005/2011 「On the safety of packaging」 governs outer packaging labelling. The user instructions (operating manual) must be supplied in Russian and optionally Kazakh. Chinese-only or English-only labelling is not compliant. The EAC mark must appear on the product and packaging alongside the required text information.TR CU 019/2011 — On the safety of personal protective equipment — labelling provisions (Section 4 / Article 7) TR CU 005/2011 — On the safety of packaging — outer packaging labelling requirements |
Full Russian-language relabelling is required for product, packaging, and user instructions. Specific gaps: (1) All text elements on the product label must be in Russian (and optionally Kazakh) — Chinese-only labels are non-compliant; (2) TR CU 019/2011 PPE-specific label elements (protection class, service life, TR reference) must be included; (3) User instructions must be translated into Russian and included in every sales unit; (4) The EAC mark must appear on both the product/mask and outer packaging; (5) Importers or authorised representatives in EAEU may apply Russian-language sticker labels over Chinese originals, but all mandatory information must be present before customs clearance.[INFORMATIONAL] Chinese-language labelling does not satisfy EAEU/Kazakhstan requirements. Full Russian-language relabelling of product, packaging, and user instructions is mandatory. The EAC mark and TR CU 019/2011-specified label elements must be present before market placement. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
| EAC Marking — Single EAEU market access mark replacing national marks | Chinese respirators certified under GB 2626-2019 (KN95) bear the CCC mark (China Compulsory Certification) if required, or a quality mark from the issuing certification body. There is no CCC mark requirement for GB 2626 industrial respirators per se, but the LA (labour protection) mark issued by authorised bodies may appear. Neither the CCC mark nor any Chinese national mark is recognised in EAEU member states. The EAC mark is the only valid conformity mark for Kazakhstan market access.GB 2626-2019 — Respiratory protective equipment — Non-powered air-purifying particle respirator (CCC scheme under CNCA where applicable) CNCA — China Compulsory Certification (CCC) mark rules |
Products subject to EAEU technical regulations, including PPE respirators under TR CU 019/2011, must bear the EAC mark (Евразийское соответствие / Eurasian Conformity) before being placed on the market of any EAEU member state including Kazakhstan. The EAC mark indicates that the product has undergone the mandatory conformity assessment procedure (EAC certification for PPE) and complies with all applicable EAEU TRs. The mark must be applied to the product itself and to the packaging; it may also appear on accompanying documentation. The EAC mark design (circle with stylised 'EAC' letters) is specified in EAEU Decision No. 711 (2012). The mark must not be applied until a valid EAC certificate of conformity is in place. Affixing the EAC mark without a certificate is a regulatory offence subject to market withdrawal and penalties.EAEU Commission Decision No. 711 (2012) — Rules for the application of the unified EAC mark of market circulation on the territory of the Customs Union TR CU 019/2011 — On the safety of personal protective equipment — marking provisions |
The EAC mark must replace or be added alongside any Chinese marks. Key gaps: (1) Chinese CCC or LA marks have no legal standing in Kazakhstan/EAEU — the EAC mark is the only recognised conformity mark; (2) The EAC mark can only be applied after a valid EAC certificate of conformity is issued by an accredited EAEU certification body; (3) The mark design must conform to EAEU Decision No. 711 specifications (dimensions, colour, placement); (4) If multiple EAEU TRs apply to the product (e.g., TR EAEU 037/2016 for electrical PPE components), the EAC mark covers all applicable TRs simultaneously once all respective conformity procedures are completed.[INFORMATIONAL] The EAC mark is the mandatory conformity mark for Kazakhstan market access. Chinese CCC or LA marks are not recognised. The EAC mark may only be applied after a valid EAC certificate of conformity is in place from an accredited EAEU certification body. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
| PPE Safety Requirements — TR CU 019/2011 and GOST EN 149 filtration / performance standards | GB 2626-2019 (KN95) specifies performance requirements for non-powered air-purifying particle respirators in China, including filtration efficiency (NaCl aerosol test, ≥95% for KN95), exhalation valve leakage, dead space CO2 content, inhalation resistance, exhalation resistance, and fit factor via fit tests. While GB 2626 and GOST EN 149 share common technical heritage (both derive from EN 149 principles), the specific test protocols, acceptance criteria, and classification systems differ. GB 2626 KN95 class broadly corresponds to EN 149 / GOST EN 149 FFP2 in filtration efficiency, but test methods are not identical and Chinese test reports cannot be substituted for GOST EN 149 compliance testing.GB 2626-2019 — Respiratory protective equipment — Non-powered air-purifying particle respirator GB 19083-2010 — Technical requirements for medical protective mask |
TR CU 019/2011 sets mandatory essential safety requirements for all PPE placed on the EAEU market. For respiratory PPE (filtering facepiece respirators), the applicable harmonised standard is GOST EN 149-2003 (harmonised with EN 149:2001+A1:2009), which specifies test methods and performance requirements for FFP1, FFP2, and FFP3 class respirators covering: particle filtration efficiency (NaCl and paraffin oil aerosol tests), inward leakage, breathing resistance (inhalation and exhalation), CO2 content, dead space, practical performance, and dolomite clogging. Devices must meet the GOST EN 149 class for which they are certified. TR CU 019/2011 additionally requires that PPE not cause harm to the user from material toxicity, ergonomic deficiency, or thermal hazard under intended use conditions.TR CU 019/2011 — On the safety of personal protective equipment — essential safety requirements (Annex 2) GOST EN 149-2003 — Respiratory protective devices — filtering half masks for protection against particles — requirements, testing, marking (harmonised with EN 149:2001+A1:2009) |
Type testing to GOST EN 149 by an EAEU-accredited laboratory is required. Key gaps: (1) Chinese GB 2626-2019 test reports do not satisfy GOST EN 149 compliance requirements — testing must be redone to GOST EN 149 protocols at an accredited EAEU laboratory; (2) While KN95 filtration efficiency (≥95%) broadly aligns with FFP2, inward leakage tests, CO2 content limits, dolomite clogging, and classification methodology differ between the two standards; (3) TR CU 019/2011 material safety requirements (no toxic materials, no harmful substances in contact with skin/respiratory tract) must be documented for all materials used; (4) If the respirator contains electrical components (e.g., powered air-purifying respirator), additional TR CU 004/2011 (LV electrical safety) requirements apply.[INFORMATIONAL] GB 2626-2019 (KN95) test reports do not satisfy GOST EN 149 requirements for Kazakhstan/EAEU market access. Full re-testing to GOST EN 149 at an EAEU-accredited laboratory is required as part of the EAC certification process under TR CU 019/2011. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
| Hazardous Substances — TR EAEU 037/2016 (RoHS-style restrictions on electrical/electronic PPE components) | China's equivalent is GB/T 26572-2011 (Requirements of concentration limits for certain restricted substances in electrical and electronic products) and the 《Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products》 (2016 revision, effective 2016-07-01). These apply to electrical and electronic equipment and are broadly analogous in scope to TR EAEU 037/2016. For powered air-purifying respirators with electronic components manufactured in China, substance restriction documentation (e.g., material declaration conforming to SJ/T 11364) may already exist and can serve as a starting point, but must be verified against TR EAEU 037/2016 specific limit values and substance list.GB/T 26572-2011 — Requirements of concentration limits for certain restricted substances in electrical and electronic products SJ/T 11364-2014 — Marking for the restriction of the use of hazardous substances in electrical and electronic products |
TR EAEU 037/2016 「On restriction of the use of hazardous substances in electrical and electronic products」 is the EAEU analogue of EU RoHS Directive 2011/65/EU. It restricts the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP) in electrical and electronic equipment. For respiratory PPE: standard passive filtering facepiece respirators (no electrical components) generally fall outside TR EAEU 037/2016 scope. However, powered air-purifying respirators (PAPRs) with battery/motor units, electronic exhalation valve actuators, or any electronic monitoring components DO fall within scope and must comply with substance restrictions. Compliance is typically demonstrated by Declaration of Conformity (DoC) for TR EAEU 037/2016 (separate from, and in addition to, the EAC certificate under TR CU 019/2011).TR EAEU 037/2016 — On restriction of the use of hazardous substances in electrical and electronic products (EAEU Council Decision No. 82, 18 October 2016) TR CU 019/2011 — On the safety of personal protective equipment (co-applicable for PPE with electrical components) |
TR EAEU 037/2016 is PRESENT and applies to respiratory PPE products with electrical/electronic components. Key gaps: (1) Passive FFP masks with no electrical components are generally out of scope — no TR EAEU 037/2016 action required; (2) PAPRs or respirators with any electronic elements must comply with TR EAEU 037/2016 substance restrictions; (3) Chinese GB/T 26572 substance documentation can serve as a reference baseline but must be mapped to TR EAEU 037/2016 limits and the 10-substance restricted list (including the 4 phthalates added beyond original RoHS); (4) A separate Declaration of Conformity for TR EAEU 037/2016 must be prepared and registered in the EAEU unified register where required.[INFORMATIONAL] TR EAEU 037/2016 (RoHS-equivalent) is PRESENT in Kazakhstan/EAEU. Passive filtering facepiece respirators (no electrical components) are generally out of scope. Powered air-purifying respirators (PAPRs) with electronic components must comply with TR EAEU 037/2016 substance restrictions and a separate Declaration of Conformity is required. Verify scope with an EAEU regulatory specialist for any respirator containing battery, motor, or electronic elements. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
| Regulatory Scope: Kazakhstan is a Full EAEU Member — TR CU 019/2011 (PPE) Applies Directly | China's respiratory PPE is governed by a three-track system: (1) Industrial/non-medical: GB 2626-2019 (KN90/KN95 particle respirators) — mandatory CCC certification under SAMR/CNCA through authorised bodies such as CQC; (2) Medical-protective: GB 19083-2010 — NMPA Class II medical device registration; (3) Surgical mask: YY 0469-2011 — NMPA Class II medical device. For export to Kazakhstan, the relevant China baseline is typically GB 2626-2019 (KN95) for industrial respiratory protection. China's LA (labour protection) product certification and CCC scheme cover the domestic side of occupational safety equipment. Neither GB 2626 test reports, CCC certificates, nor NMPA registrations are recognised as satisfying TR CU 019/2011 EAC certification requirements for Kazakhstan market access.GB 2626-2019 — Non-powered air-purifying particle respirator (KN90/KN95) — SAMR/CCC mandatory GB 19083-2010 — Technical requirements for medical protective mask — NMPA Class II YY 0469-2011 — Medical surgical mask — Technical requirements — NMPA Class II |
Kazakhstan is a founding full member of the Eurasian Economic Union (EAEU) and has been since the EAEU Treaty entered into force on 1 January 2015 (previously within the Customs Union from 2010). This membership status is commercially decisive for respiratory PPE exporters: EAEU Technical Regulation TR CU 019/2011 「On the safety of personal protective equipment」 applies directly and uniformly across all EAEU member states including Kazakhstan, Russia, Belarus, Armenia, and Kyrgyzstan. Filtering facepiece respirators and particle respirators are explicitly covered under TR CU 019/2011. Mandatory conformity assessment takes the form of EAC certification (not declaration) for PPE, administered by EAEU-accredited conformity assessment bodies. The national regulatory authority in Kazakhstan is Gosstandart (Committee for Technical Regulation and Metrology, under the Ministry of Trade and Integration). EAC certification obtained in any EAEU member state is valid across all member states including Kazakhstan — there is no separate Kazakhstan-only certification. Products must bear the EAC mark before market placement. TR EAEU 037/2016 (restriction of hazardous substances in electrical/electronic products) also applies as an EAEU-wide regulation for any PPE products with electrical components.TR CU 019/2011 — On the safety of personal protective equipment (Decision of the Customs Union Commission No. 878, 9 December 2011) — directly applicable in Kazakhstan TR EAEU 037/2016 — On restriction of the use of hazardous substances in electrical and electronic products — applicable for PPE with electrical components Treaty on the Eurasian Economic Union (29 May 2014, entered into force 1 January 2015) — Kazakhstan full membership |
Kazakhstan is a full EAEU member — TR CU 019/2011 applies in full. Key gaps: (1) Unlike non-EAEU countries (e.g., Uzbekistan), Kazakhstan does not operate a separate national certification regime for PPE — the EAEU TR CU framework is the mandatory route; (2) An EAC certificate obtained from any EAEU-accredited certification body covers all EAEU member states including Kazakhstan — no separate Kazakhstan-only certificate is needed; (3) Chinese GB 2626 test data, CCC certificates, and LA marks are not accepted as substitutes for EAC certification; (4) The EAEU accredited certification body must conduct type testing to GOST EN 149 (the harmonised standard for filtering facepiece respirators); (5) TR EAEU 037/2016 additionally applies to any PPE with electrical/electronic components — a separate declaration of conformity under this regulation is required where applicable; (6) Ports of entry include Khorgos land border crossing (China-Kazakhstan) and Aktau sea port — ensuring EAC marking and Russian-language documentation is complete before shipping is essential.[INFORMATIONAL] Kazakhstan is a full EAEU member — TR CU 019/2011 applies directly. Mandatory EAC certification (not declaration) by an EAEU-accredited body is required for respiratory PPE. An EAC certificate valid across all EAEU member states may be obtained from any accredited body regardless of where it is domiciled. Chinese GB 2626 certificates and CCC documentation are not recognised as satisfying this requirement. TR EAEU 037/2016 (RoHS-equivalent) is PRESENT and applies to PPE products with electrical/electronic components. | Eurasian Economic Commission (EEC) — Official EAEU legal portal2026-06-16 · reference |
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- Eurasian Economic Commission (EEC) — Official EAEU legal portal · accessed 2026-06-16 · reference · used in 4 rows
- Eurasian Economic Commission (EEC) — Official EAEU legal portal · accessed 2026-06-16 · reference · used in 1 rows
- Eurasian Economic Commission (EEC) — Official EAEU legal portal · accessed 2026-06-16 · reference · used in 1 rows