Uzbekistan

Advertising in Uzbekistan is under increasingly close regulatory oversight, marking a new stage in the development of the country’s media and marketing landscape. This evolution is driven by two converging factors: the rapid growth of consumer activity in digital spaces and the state’s expanding focus on compliance and transparency across both traditional and online forms of advertising. At the forefront of this regulatory process stands the Anti-Monopoly Committee of the Republic of Uzbekistan, which conducts regular monitoring exercises to identify and address breaches of the Law “On Advertising”. While its oversight historically concentrated on outdoor advertisements – billboards, banners, and other public displays, the Committee has increasingly turned its attention to the digital environment, where violations can spread more quickly and reach a broader audience. In today’s Uzbekistan, social media platforms such as Telegram, Facebook, Instagram, and LinkedIn have become the dominant channels for marketing and brand communication. This transition from physical to digital advertising has prompted broader discussions on consumer protection, emphasizing the importance of truthful, transparent, and ethical promotion in the online sphere. It has also exposed gaps in the existing legal framework, reinforcing the government’s efforts to modernize the country’s advertising laws in line with the realities of an increasingly digital economy. Legal Framework The primary piece of legislation governing advertising in Uzbekistan is the Law of the Republic of Uzbekistan “On Advertising”. The law establishes general requirements for advertising content, including truthfulness, fairness, and the protection of minors and consumers from misleading or unethical marketing. The advertising framework in Uzbekistan is further supported by several complementary legal and administrative instruments. The Law “On Protection of Consumer Rights” establishes safeguards against misleading or unfair advertising and provides mechanisms for consumer compensation, while the Law “On Trademarks, Service Marks and Appellations of Origin of Goods” clarifies the lawful use of trademarks in promotional materials and protects rights holders against unauthorized or deceptive references. The regulation of outdoor advertising is additionally supported by a series of Cabinet of Ministers resolutions, notably Resolution No. 104 of 20 February 2020 “On Regulation of the Outdoor Advertising Market”, together with Resolutions No. 702 of 30 August 2018 and No. 428 of 31 August 2023, which further elaborate on coordination procedures, technical and safety standards, and municipal approval processes. Language requirements Uzbek law requires that all advertising distributed within the country be presented in the state language (Uzbek).[1] However, the use of foreign languages is permitted, provided that the Uzbek version is also available and that the foreign-language text does not distort or misrepresent the meaning of the original message. For outdoor advertising, the translated text must be placed horizontally at the bottom of the Uzbek-language text and may not exceed 40% of the total advertising area. For television, radio and print media, translated advertising in other languages must not exceed 20% of the total daily volume of advertising. The font of any translated text must be smaller than the font of the Uzbek-language text.[2] Exceptions to these limits apply where media are produced exclusively in a foreign language (for example, print editions or broadcasts in a foreign language and websites that publish only in foreign languages).[3] One of the practical advantages of having a registered trademark in Uzbekistan is that it allows the brand owner to use the mark in its original linguistic and graphic form, regardless of whether it is in Uzbek or a foreign language.[4] A registered trademark enjoys legal protection in the exact form in which it is registered, be it Latin, Cyrillic, or any other script, and may therefore appear in advertisements without translation. By contrast, if a foreign-language brand or logo has not been registered as a trademark in Uzbekistan, advertisers are generally expected to provide a translation or transliteration into Uzbek to avoid claims of misleading consumers or violating language-use requirements. This framework reflects a balanced approach, it safeguards the linguistic rights of consumers while giving brand owners a clear incentive to secure trademark protection locally, ensuring full freedom to use their brand identity across all media channels. Sector-Specific Restrictions Alongside the general language requirements, Uzbek advertising law also imposes standard sector-specific restrictions that apply to certain sensitive industries. Stricter rules govern the promotion of pharmaceuticals, supplements, energy drinks, alcohol, financial and insurance services, and products intended for minors.[5] The law expressly prohibits advertising of certain goods, including tobacco products, gambling and breast milk substitutes.[6] A limited exception applies to alcoholic beverages such as beer, natural and sparkling wines, which may be advertised only under specific conditions, for example, in venues where tasting, demonstrations, or brand events are held, and in compliance with strict content and restrictions established by law.[7] IP Issues in Advertising Advertising activities are closely linked with intellectual property rights, particularly trademark and copyright law. Under the Law “On Trademarks, Service Marks, and Appellations of Origin of Goods”, the use of a trademark in advertising is recognized as one of the forms of trademark use.[8] This means that if a company uses another party’s trademark in its advertisement without consent, such use may constitute trademark infringement, even if the advertisement itself appears lawful under advertising law. Uzbek legislation permits comparative advertising, for example, where a product’s features are contrasted with that of competitors. However, such comparisons must be factually substantiated and not defamatory.[9] Comparative advertising that discredits a competitor’s business reputation, goods, or trademarks may be deemed unlawful.[10] In other words, comparative advertising is allowed only when it remains truthful, objective, and non-misleading. Advertisers must also respect copyright protections. Copying, reproducing, or imitating another party’s artistic works, text, design elements, or music without permission is prohibited and may give rise to liability.[11] In practice, these overlapping regimes mean that advertising in Uzbekistan must be both creatively persuasive and legally cautious. Marketing campaigns that reference competitors or borrow artistic elements should undergo prior legal review to ensure compliance with IP and advertising legislation alike. Outdoor Advertising Outdoor advertising in Uzbekistan is subject to specific regulatory requirements, reflecting its impact on urban design and public safety. The installation of billboards, pylons, signs, and other outdoor advertising structures requires obtaining an official “advertising place passport”— a document granting the right to place the construction at a particular site or building.[12] The placement schemes for such advertising structures are approved by local authorities and must comply with urban planning and architectural regulations.[13] All structures must also meet technical safety standards, including requirements for structural strength, secure installation, and minimum distance from roads and pedestrian areas.[14] Advertising objects erected without a valid passport are considered unauthorized and may be dismantled by competent authorities.[15] Holders of advertising places are required to pay prescribed fees in a timely manner, failure to do so can result in revocation of the passport and re-auctioning of the advertising site through an electronic bidding platform.[16] Furthermore, the law prohibits outdoor advertising on cultural heritage sites, road signs, traffic lights, and other urban infrastructure elements, underscoring the balance between commercial expression and public interest.[17] Liability for infringement Liability for breaches of advertising rules under Uzbek law encompasses both administrative and civil measures. Under the Code of the Republic of Uzbekistan on Administrative Liability, fines are imposed on advertisers, producers, and distributors depending on their role in the dissemination of unlawful advertising. Advertisers bear responsibility for the content and accuracy of the information; producers are liable for the preparation of the advertising material; and distributors, including television channels, online platforms, and outdoor operators, are accountable for compliance with placement, timing, and form requirements.[18] Administrative penalties apply for misleading or prohibited advertising, failure to carry out “counter-advertising” when ordered by the regulator, or breaches of disclosure obligations.[19] The amount of fines varies depending on the severity of the violation, ranging from thirty to one hundred basic calculation units (BCUs). As of today, one BCU equals UZS 412,000 (approximately USD 35). Accordingly, fines may range from about USD 1,050 to USD 3,500. In particular, unlawful advertising of prohibited or restricted products is punishable by a fine of up to 100 BCUs (≈ USD 3,500); misleading advertising or failure to publish counter-advertising — up to 70 BCUs (≈ USD 2,450); breaches related to alcohol, tobacco, energy drinks, weapons, or outdoor advertising — up to 50 BCUs (≈ USD 1,750); and violations concerning advertising aimed at minors or involving pharmaceuticals, biologically active additives, or child nutrition — up to 30 BCUs (≈ USD 1,050). [20] From a civil perspective, consumers misled by false or deceptive advertising may seek compensation for damage caused by reliance on such information.[21] Additional sanctions may include suspension of advertising activities or revocation of permits for outdoor advertising. The Anti-Monopoly Committee of Uzbekistan serves as the primary enforcement body overseeing compliance with advertising law. It has the authority to investigate breaches, issue binding orders to cease unlawful advertising, and require the publication of corrective materials even prior to judicial proceedings.[22] Expected Amendments Uzbekistan’s advertising and media landscape is rapidly evolving alongside the country’s broader digital transformation. While the current legal framework provides a solid basis for regulating traditional forms of advertising, online and digital platforms remain relatively underregulated. This gap has become increasingly evident with the growth of social media marketing, influencer collaborations, and online marketplaces, which now dominate much of the country’s promotional activity. Recognizing this challenge, the government has initiated a series of legislative reforms aimed at strengthening consumer protection in the digital sphere. In March 2025, a draft Law “On the Protection of Rights of Users of Online Platforms and Websites” was introduced for public discussion. The proposed law introduces a comprehensive framework to regulate online content, advertising practices, and the responsibilities of digital actors including bloggers, influencers, and platform operators thereby addressing long-standing gaps in the regulation of digital media and online advertising. If enacted, this law would mark a major step in aligning Uzbekistan’s digital ecosystem with international trends, bridging the gap between the Law “On Advertising”, Law “On Informatization”, and consumer protection legislation. It would also formally extend the state’s oversight over online advertising content, particularly influencer marketing, a domain that has so far remained largely outside the scope of existing regulation. Conclusion Uzbekistan’s advertising regulation is undergoing a period of modernization marked by enhanced transparency mechanisms, digital monitoring tools, and an expanded scope of liability. While the Law “On Advertising” remains the central legal instrument, accompanying sectoral and administrative acts reflect the government’s commitment to building a more accountable and competitive advertising environment. For international businesses, these developments introduce both opportunities and compliance challenges, as stricter content standards, electronic monitoring systems, and forthcoming rules for influencers and online platforms will require careful adaptation to the evolving framework. Companies that proactively align their advertising strategies and contractual arrangements with these emerging regulatory requirements will be best positioned to operate transparently, protect their brand reputation, and maintain consumer trust in Uzbekistan’s market. Authors: - Jamshid Agzamkhadjaev (Managing Partner, Settle Law Firm) - Saida Djunaydullaeva (Paralegal, Settle Law Firm) References [1] Law of the Republic of Uzbekistan “On Advertising” No. ZRU-776 of 7 June 2022, Art. 6 (1). [2] Ibid, Art. 6 (2). [3] Ibid, Art. 6 (3). [4] Ibid, Art. 6 (4). [5] Ibid, Art. 34, 35, 37, 38, 42-45. [6] Ibid, Art. 36, 40, 41, 46. [7] Ibid, Art. 39. [8] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin of Goods” No. 267-II of 30 August 2001, Art. 27 (2). [9] Law of the Republic of Uzbekistan “On Advertising” No. ZRU-776 of 7 June 2022, Art. 16 (2). [10] Ibid, Art. 16 (2). [11] Ibid, Art. 4. [12] Ibid, Art. 25. [13] Ibid, Art. 23 (7). [14] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 104 of 20 February 2020 “On Regulation of the Outdoor Advertising Market”. [15] Law of the Republic of Uzbekistan “On Advertising” No. ZRU-776 of 7 June 2022, Art. 25 (6). [16] Ibid, Art. 24 (3). Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 104 of 20 February 2020 “On Regulation of the Outdoor Advertising Market”, para. 96 (e). [17] Law of the Republic of Uzbekistan “On Advertising” No. ZRU-776 of 7 June 2022, Art. 26 (3). [18] Ibid, Art. 49. [19] Ibid, Art. 47. [20] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 104 of 20 February 2020 “On Regulation of the Outdoor Advertising Market”, para. 96 (e). [21] Law of the Republic of Uzbekistan No. 221-I of 26 April 1996 “On Protection of Consumer Rights”, Art. 7 (3). [22] Law of the Republic of Uzbekistan “On Advertising” No. ZRU-776 of 7 June 2022, Art. 8.

On 12 May 2025, the Minister of Health of the Republic of Uzbekistan (the “Uzbekistan”) issued the Order “On Amendments and Additions to the Order ‘On Approval of the Regulation on the Procedure for Accounting Medicine Prices within the Reference Pricing System’” No. Order-3242–1 dated 12 May 2025 (the “Order No. 3242–1”). Below is an overview of the key changes introduced to the regulation of the reference pricing for prescription medicines as set forth in the Order No. 3242–1. Deregulation of prices to OTC medicines Pursuant to the Order No. 3242–1, in the Regulation “On Approval of the Procedure for Accounting Medicine Prices within the Reference Pricing System” (the “Regulation”), approved by the Order of the Minister of Health of Uzbekistan No. Order-3242 dated 10 June 2020, the term “medicine” has been replaced with “prescription medicine.” As a result of these changes, the Regulation now governs prices solely for prescription medicines. Update of the List of Reference Countries In accordance with the Order No. 3242–1, Annex No. 2 to the Regulation, which contains the list of reference countries (the “List”), has been revised. Specifically, the List now excludes the following countries: the Republic of Tajikistan, the Republic of Slovenia, and the Kyrgyz Republic. At the same time, the List has been supplemented with the following countries: the Arab Republic of Egypt, the Republic of Turkey, and the Republic of Romania. Introduction of an Alternative Procedure for Price Confirmation in the Absence of Data from Reference Countries The Regulation has been supplemented with a provision establishing an alternative procedure for confirming prices of imported prescription medicines when price information is unavailable from two or more reference countries. In such cases, the applicant must provide an export customs declaration issued in the country of manufacture. If the declaration does not indicate the value of the produce or if the legislation of the country of origin does not require an export declaration, an alternative replacement document may be submitted. Specifically, such a document may be an agreement between the manufacturer and the distributor, provided the agreement is registered in the country of origin and includes the following information: the name and details of the exporter and importer, the value and quantity of the goods imported into the customs territory of Uzbekistan. Introduction of an Automatic Indexation Mechanism for Maximum Prices In accordance with the Order No. 3242–1, the maximum prices of imported prescription medicines in the register of maximum prices during their registration or re-registration are subject to automatic indexation to the national currency of Uzbekistan. The indexation is performed twice a year – on 1 January and 1 July – based on the official foreign currency exchange rate set by the Central Bank of Uzbekistan. Automatic indexation applies only to medicines whose last recorded maximum price has increased by at least 3% as a result of an increase in the foreign currency exchange rate relative to the price of the medicine in the national currency. If the increase in the foreign currency exchange rate causes the last recorded maximum price to rise by more than 5%, automatic indexation is carried out regardless of the scheduled dates of planned maximum price indexation (1 January and 1 July of each year). Revised Terms and Grounds for Re-registration of Maximum Prices for Medicines According to the amendments, an application for re-registration may be submitted no earlier than six months from the date of the initial registration of the maximum price. The revised Regulation stipulates that an application for re-registration of maximum prices may be submitted no earlier than six months from the date of the maximum price registration. The applicant is required to attach supporting documents specifying the particular reasons for the price increase. Furthermore, the Order No. 3242–1 revised the grounds for re-registration of maximum prices for prescription medicines. The updated Regulation provides that re-registration of maximum prices before the established six-month period is allowed exclusively in the event of force majeure circumstances arising in the country of manufacture of the respective medicines. Introduction of a Calculation Form for the Selling Price of Domestic Medicines In accordance with the Order No. 3242–1, a new Annex No. 1 has been added to the Regulation, establishing the form for calculating the selling price of domestic prescription medicines. The form is structured according to the main cost categories and includes the following elements: the cost price of the medicine, detailed by its constituent components, other expenses, including administrative costs, promotional expenses, operational, and financial costs, the total expenses line, calculated as the sum of all specified costs, the net profit margin expressed as a percentage, the calculation of the retail price per packaging unit of the medicine – both excluding and including VAT. General Amendments to the Regulation Expanded Obligations of the Pharmaceutical Industry Development Agency  Regarding the Publication of Information on Maximum Prices According to the amendments introduced by the Order No. 3242–1, the Pharmaceutical Industry Development Agency is now required to continuously publish this information on registered and re-registered maximum prices on the Unified Portal of Interactive Public Services, in addition to the official website of the Pharmaceutical Industry Development Agency. The Maximum Share of Other Expenses Increased from 1% to 2% The Regulation was amended to revise the procedure for applying maximum trade margins in wholesale and retail sale of imported and domestic medicines, as well as the formula for calculating their purchase cost. Specifically, the “other expenses” (OE) component, included in the purchase cost, may now constitute up to 2% (previously 1%) of the contract price set under Incoterms CIP terms.   Priority Tasks Identified for Improving the Quality of Medical Services and Enhancing the Medical Education System On 7 May 2025, a video conference chaired by the President of Uzbekistan, Shavkat Mirziyoyev, was held to discuss issues related to improving the quality of medical services at the primary care level and specialized institutions, regulating the consumption of medicines, and enhancing the medical education system. Following the conference, a number of regulatory legal acts were adopted to implement the measures discussed at the conference. Among them are the Presidential Decree of Uzbekistan “On Measures for the Consistent Continuation of Healthcare Reform through the Improvement of the System and Principles of Medical Service Delivery to the Population in the Republic” No. UP-88 dated 19 May 2025 (the “UP №88”) and the Presidential Resolution of Uzbekistan “On Additional Measures for the Implementation of Reforms in the Healthcare System” No. PP-185 dated 19 May 2025 (the “PP №185”), which provide for measures aimed at further development of the healthcare system. According to the UP №88, inter alia, it is envisaged to introduce a new system of primary healthcare delivery, launch a new model for organizing the healthcare system as a pilot project, and increase the salaries of healthcare workers. In turn, the PP №185 sets out, inter alia, the goals and objectives aimed at implementing the pilot project, optimizing the staffing structure of the primary healthcare level, and reorganizing district healthcare institutions. Further details on the measures aimed at reforming the healthcare system are provided below. Strengthened Control of Prescription and Consumption of Medicines During the conference, it was noted that international best practices prioritize the principles of evidence-based medicine, according to which only medicines whose efficacy and safety have been confirmed by large-scale clinical trials are approved for use. At the same time, in Uzbekistan, medicines with unproven efficacy account for approximately 42% of total imports. In this regard, the President of Uzbekistan instructed the Ministry of Health to: exclude from clinical protocols medicines recognized internationally as ineffective or insufficiently studied, conduct an audit of the justification for antibiotic prescriptions in all medical institutions, with a primary focus on pediatric hospitals. Measures Approved for the Phased Implementation of Structural Changes in the Healthcare System The President addressed issues related to improving primary healthcare, disease prevention, enhancing the qualifications of medical personnel, and improving the quality of treatment. A new model for organizing the healthcare system was approved, which includes the following key measures for the phased reform of the healthcare system:   Reform of the Primary Care. The practice of concluding bilateral agreements between family medical teams and the assigned population will be introduced. Citizens will have the opportunity to freely choose their family doctor, and private medical institutions will be involved in providing medical care. The updated model of primary health care will be implemented in 2025 in the city of Samarkand, the Ishtikhan and Bulungur districts of the Samarkand region, as well as in one district of each of the other regions of the Republic. Starting from 2027, its implementation will be carried out gradually throughout the territory of Uzbekistan. It is worth noting that, in accordance with the UP №88, the implementation of the updated model of primary healthcare in the city of Samarkand, as well as in Ishtikhan and Bulungur districts of Samarkand region, has been postponed from 2025 to 2026. In execution of the UP №88, the Cabinet of Ministers of Uzbekistan adopted the Resolution “On Measures for the Implementation of the Pilot Project to Improve the Primary Healthcare System in the Republic” No. PKM-384 dated 20 June 2025 that provides for implementation of the pilot project for improving the primary healthcare system, Guaranteed Medical Care Package. Medical services and medicines included in this package will be fully covered by the state budget. These measures were subsequently reflected in the PP №185 and were further elaborated in the Resolution of the Cabinet of Ministers of Uzbekistan “On the Approval of Guaranteed Volumes of Medical Care Covered by the State Budget of the Republic of Uzbekistan in Primary Healthcare Institutions” No. PKM-382 dated 19 June 2025, Optimization of Staffing. All primary care physicians and nurses will be transferred to fulltime employment. The number of obstetrician-gynecologists in polyclinics will be doubled. A separate pediatrician position will be established for every 3,000 children, Reorganization of District Healthcare Institutions. District central polyclinics will be transformed into consultative and diagnostic departments within district hospitals, where specialized narrow-profile specialists will be concentrated. Seven large polyclinics serving more than 12,000 people will be reorganized, and 27 will be converted into smaller facilities, Increase in Salaries for Medical Workers. The base salary for a family doctor will be the equivalent of USD 500, and for a nurse — USD 300. An additional allowance of the same amount will be paid upon presentation of a qualification certificate. For active work in the mahalla (including prevention of complications, management of chronic diseases, early detection of cancer, myocardial infarction, stroke, diabetes), the salary will be further increased. The pilot implementation of this system is scheduled to begin on 1 July 2025 in 15 selected districts and cities across the regions of Uzbekistan. From 1 January 2026, this pilot project will be rolled out across the territory of the Samarkand region, Simplification of the Disability Determination Procedure. Starting from 1 June, a system for establishing disability without the involvement of medical advisory commissions will be implemented in the city of Tashkent and the Navoi region, and from 1 September – across the entire territory of Uzbekistan. Disability will be determined solely based on the conclusion of the family doctor and review by the Medical and Social Expertise Commission, Financing of Reforms. For the implementation of the new model in 15 pilot districts in 2025, UZS 285 billion has been allocated. Additionally, local authorities are required to allocate at least UZS 10 billion from local budgets. Comprehensive Measures on Modernizing Medical Care and Healthcare Financing Discussed During a conference, issues related to improving the efficiency of specialized medical care and enhancing its financing mechanisms were also discussed. Current Situation of Specialized Medical Care Reviewed A decision was made that in republican medical centers, only high-tech and complex surgical interventions will be performed, financed exclusively by the state budget. Enhancement of the “Electronic Referral” System The “electronic referral” system will be modernized. In particular: a list of diseases subject to referral through the electronic system will be approved, a unified base tariff for medical services will be established, after a referral is issued, patient information will be uploaded to a unified digital platform accessible to both public and private medical institutions, patients will have the opportunity to independently select a medical institution based on the available options. A total of UZS 1.1 trillion from the state budget is allocated for financing treatment under the electronic referral system in 2025. In this context, the digitalization of the healthcare system is reflected in the UP №88. New Five-Year Program to Combat Childhood Cancer Developed A five-year program to combat childhood cancer will be developed, similar to the existing national oncology program, with a budget allocation of at least USD 110 million. As part of the program, an academic hub specializing in the diagnosis and treatment of childhood cancer will be established at the Center for Pediatric Oncohematology. International experts and leading specialists from foreign clinics will be actively involved in its activities. In accordance with these measures discussed during the video conference, the Presidential Decree of Uzbekistan No. PP-186 dated May 19, 2025, “On Measures for the Implementation of the National Strategy of Uzbekistan on Combating Childhood Cancer for 2025–2030,” provides for the establishment of an International Academic Hub on Childhood Cancer in the form of a state institution, with the support of clinics from leading European universities. In turn, the Resolution of the Cabinet of Ministers of Uzbekistan No. PKM-326 dated May 22, 2025, “On Measures for the Organization of the Activities of the International Academic Hub on Childhood Cancer,” establishes the operational framework for the International Academic Hub’s functioning. Measures to Improve the Quality of Medical Education In order to enhance the quality of medical personnel training, the following measures were approved at the conference: Implementation of an independent knowledge assessment system for graduates of medical universities and colleges, as well as practicing doctors and nurses. For this purpose, a National Center for Medical Assessment will be established. Mandatory accreditation of all public and private medical institutions. Transfer of responsibilities for continuing medical education to public and private medical universities, specialized centers, and regional medical institutions. Introduction of dual education in the medical field. In this regard: ❖ existing clinics will be transferred under the management of medical universities, ❖ medical universities will be granted financial autonomy. Specific Instructions Regarding Regional Medical Universities: Grant financial autonomy to medical universities in the Republic of Karakalpakstan, Fergana Region, and the city of Urgench, Transfer the clinics of medical universities in the Republic of Karakalpakstan, Bukhara, Samarkand, Tashkent, Fergana Regions, and the city of Urgench into the organizational structure of the respective medical universities, Assign management of medical activities in the departments of these clinics to the relevant university faculties, Hold the rectors of the medical universities responsible for the maintenance and equipping of subordinate institutions that serve as clinical bases.   Contacts:               Zafar Vakhidov Partner, Vakhidov & Partners Uzbekistan / Kazakhstan [email protected]     Kamila Sharipova Senior Associate, Vakhidov & Partners Uzbekistan [email protected]        

On January 28, 2025, the President of the Republic of Uzbekistan (“Uzbekistan”) signed the Decree “On Additional Measures for the Accelerated Development of the Pharmaceutical Industry” No. UP13 (the “Decree No. 13”), which came into force on January 29, 2025. Below is an overview of the key regulatory changes in the pharmaceutical industry introduced by the Decree No. 13. The most significant amendments include the abolition of price markup limitations on over-the-counter medicines and the imposition of a 2% customs duty on certain categories of medicines, effective April 1, 2025. Abolition of maximum price markups on over-the-counter medicines as of April 1, 2025 Pursuant to the Decree No. 13, as of April 1, 2025, maximum price markups (15% for wholesale and 20% for retail sales) will apply only to prescription medicines. Accordingly, regulatory restrictions on price markups for over-the-counter medicines will no longer be in effect. Notably, the Decree No. 13 does not provide a clear explanation regarding the retention or removal of price markups on medical devices. Furthermore, the Decree No. 13 stipulates that the current reference pricing system shall remain in effect for domestic and imported prescription medicines, subject to the following conditions: The certification of prescription medicines is prohibited if their reference price is not indicated or exceeds the established reference price, If the same manufacturer produces medicines with an identical composition under different trade names, the lowest reference price shall apply to all such products. This rule does not apply in cases where active pharmaceutical ingredients from various manufacturers are used in the production of these medicines, The State Enterprise "Pharmaceutical Safety Center" (the "Pharmaceutical Safety Center") shall automatically adjust reference prices denominated in foreign currency without requiring the applications from businesses. If the exchange rate increases by 3%, adjustments shall be made twice a year (in January and July), and if the exchange rate increases by 5%, an unscheduled adjustment shall be carried out. Introduction of a 2% customs duty on certain categories of medicines Pursuant to the Decree No. 13, effective April 1, 2025, a 2% customs duty will be imposed on medicines classified under heading 3004 of the Foreign Economic Activity Commodity Nomenclature, based on their customs value. Furthermore, the exemption from customs duties has been extended until January 1, 2028, for technological and laboratory equipment, components, and spare parts not manufactured in Uzbekistan, as well as raw materials, substances, medical devices, and packaging used for preclinical research and medicine production, imported for own needs of pharmaceutical manufacturers and wholesale pharmaceutical trading enterprises. The relevant amendments have been introduced into the Decree No. UP-55, "On Additional Measures for the Accelerated Development of the Pharmaceutical Industry of Uzbekistan for 2022–2026," dated January 21, 2022. Requirements for the export of donor blood plasma from Uzbekistan for medicine production established Pursuant to the Decree No. 13, the proposal of the Ministry of Health and the Agency for the Development of the Pharmaceutical Industry under the Ministry of Health (the "Agency") has been approved, allowing for the export of donor blood plasma from Uzbekistan until the end of 2027 for the contractual production of medicines derived from donor blood plasma. The basis of the decision to export donor blood plasma is the conclusion issued by the Ministry of Health and the Agency. The surplus volumes of medicines produced from the exported donor blood plasma, exceeding the needs of the Ministry of Health, are allowed to be sold (exported) to foreign countries. The Ministry of Health has been instructed to submit a draft government resolution to the Cabinet of Ministers of Uzbekistan by March 1, 2025, which shall establish: The procedure for granting permission to export donor blood plasma from Uzbekistan for medicine production, The procedure for authorizing the export of medicines produced from donor blood plasma to foreign countries. Comprehensive measures adopted to stimulate the development of the pharmaceutical industry A plan for comprehensive measures has been developed to further reform the pharmaceutical industry and ensure the population's access to high-quality medicines The Decree No. 13 introduces a set of measures aimed at further reforming the pharmaceutical sector and improving the availability of high-quality medicines, including: Analysis of the application of value-added tax (VAT) on medicines and the development of proposals for improving this system by the Ministry of Economy and Finance, the Tax Committee, and the Agency, Enhancement of pharmaceutical product certification rules, including improvements to the sample identification process within certification regulations, the establishment of an appeal procedure for applicants contesting certification decisions issued by the Pharmaceutical Safety Center, improvements to the electronic certification system, increased automation of assessment processes, and the full formation of an electronic database, Development of a legal and regulatory framework for the production of biotechnological pharmaceuticals based on cell technologies, Development and submission to the Cabinet of Ministers of Uzbekistan of a draft government resolution on the establishment of a Regenerative Medicine Center, as well as measures for organizing its activities by the Ministry of Health, Provision of state medical institutions with the necessary equipment for record keeping of the medicines procured for patient treatment for reporting purposes. Approval of the Establishment of a Venture Fund and an Investment Fund for the Development of the Pharmaceutical Industry Pursuant to the Decree No. 13, the proposal of JSC "Asakabank" and the Agency to establish a venture fund under the founding ownership of JSC "Asakabank" has been approved, with a deadline set for the end of March 2025. The venture fund, to be registered in the form of a limited liability company, will have an authorized capital of USD 10 million and will finance startup projects in key pharmaceutical sectors, including biopharmaceuticals, cell technologies, and oncology research. At the same time, the Reconstruction and Development Fund, JSC "Asakabank," and the Agency are to establish the Investment Fund for Prospective Pharmaceutical Industry Projects (the "Investment Fund") under JSC "Asakabank" with no separate legal identity. The Reconstruction and Development Fund and JSC "Asakabank" will each contribute USD 50 million to the Investment Fund. The Investment Fund is authorized to participate in equity financing in applied research and investment projects within the pharmaceutical sector. The formation of the Investment Fund’s resources will be contingent upon the approval of pharmaceutical industry investment projects, with the following requirements: Feasibility studies of projects financed by the Investment Fund shall be subject to the review by the Scientific and Technical Council under the Agency, Import contracts within these projects shall be assessed by the State Unitary Enterprise "Center for Comprehensive Expertise of Projects and Import Contracts". Within two months, the Reconstruction and Development Fund, JSC "Asakabank," and the Agency are required to submit a draft Regulation on the Investment Fund for consideration by the Cabinet of Ministers of Uzbekistan. Financing Scientific Research and Startups in the Pharmaceutical Industry Pursuant to the Decree No. 13, the Ministry of Higher Education, Science, and Innovation, in cooperation with the Ministry of Economy and Finance, has been tasked with ensuring the annual allocation of up to UZS 20 billion from the State Budget to the Science and Innovation Support Fund until 2030. The allocated funds will be utilized within state programs for scientific activities, specifically for: Integrating projects into incubation and acceleration programs, Financing scientific research conducted by the Agency for Innovative Development, aimed at the development of domestic medicines, Supporting the Agency's startup projects in the pharmaceutical industry. Support Measures for Reimbursement of Registration Costs and Participation in International Exhibitions and Fairs of Domestic Pharmaceutical Manufacturers Pursuant to the Decree No. 13, the Trade Facilitation Fund is authorized to provide financial compensation to domestic pharmaceutical manufacturers based on their stability rating, as follows: 100% reimbursement of expenses related to the registration of medicines by domestic manufacturers with the US Food and Drug Administration (FDA) or the European Medicines Agency (EMA), upon submission of supporting registration documents, 50% reimbursement of expenses incurred for the registration of pharmaceutical products by domestic manufacturers in foreign countries, upon submission of supporting registration documents. Additionally, the Trade Facilitation Fund will introduce a 100% prepayment mechanism to cover the participation costs of domestic pharmaceutical enterprises in prestigious international exhibitions and fairs with exhibition stands, based on applications submitted by the Agency. Agency's Structural Unit to Provide Consulting Support to Pharmaceutical Enterprises Pursuant to the Decree No. 13, the State Enterprise "Pharm Service" is being established within the organizational structure of the Agency. The institution will specialize in providing marketing and consulting services aimed at assisting pharmaceutical enterprises in the implementation of advanced industry standards. The State Enterprise "Pharm Service" has been assigned the following core areas of activity: Supporting domestic pharmaceutical enterprises in registration of pharmaceutical products, providing legal and consulting assistance in the implementation of national and international standards, as well as offering marketing services, Facilitating the participation of domestic enterprises in prestigious international pharmaceutical exhibitions and fairs, including assistance in organizing exhibition stands, Overseeing the digitalization of the pharmaceutical industry, Providing consulting services on the design and construction of pharmaceutical enterprises. The funding sources for the State Enterprise "Pharm Service" include: Funds from the Pharmaceutical Industry Support and Development Fund, Revenue from paid services, Charitable donations from individuals and legal entities. Additional Responsibilities Assigned to the Agency and WHO Prequalification Requirement for the Pharmaceutical Safety Center Laboratory Pursuant to the Decree No. 13, the Agency has been assigned an additional responsibility — the development of the biologically active supplements and cosmetic products industry. This includes market research and analysis, product localization, and facilitating the adoption of advanced international practices and standards by industry enterprises. Additionally, under the Decree No. 13, the Ministry of Health has been instructed to ensure that the Pharmaceutical Safety Center Laboratory undergoes the World Health Organization (WHO) prequalification process by the end of 2025. This certification will confirm the laboratory’s compliance with international standards and regulations for conducting chemical and microbiological research.   Contacts:             Zafar Vakhidov Partner, Vakhidov & Partners Uzbekistan / Kazakhstan [email protected]   Kamila Sharipova Senior Associate, Vakhidov & Partners Uzbekistan [email protected]        

On July 18, 2025, by order of the Director of the National Agency for Advanced Projects  No. 3631, the Regulation on the Procedure for Carrying out Courier Service Activities in Ecommerce (hereinafter referred to as the "Regulation") was approved. The document was adopted in accordance with the Law on E-Commerce and the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan on Measures for the Further Development of the ECommerce Sector in the Republic of Uzbekistan dated December 26, 2024, No. 885, which highlights the priority of digitalizing trade and enhancing e-commerce standards in the Republic of Uzbekistan. The Regulation mainly focuses on issues of transparency, safety, and adherence to sanitary standards in goods’ delivery, especially concerning the transportation of food products. The Regulation introduces several new concepts in the sphere of courier services in ecommerce, such as the information system (IS) of the e-commerce operator, courier, delivery service operator, and delivery service.   According to the Regulation, couriers may be individuals, including self-employed persons, who provide goods delivery services under employment contracts or civil law contracts entered into with business entities, sellers, manufacturers, catering establishments, and delivery service operators.   A delivery service operator, in turn, must be a resident of the Republic of Uzbekistan who provides goods delivery services under an agreement with e-commerce operators or arranges delivery of orders to customers via couriers. Notably, unlike e-commerce operators, delivery service operators may be not only legal entities, but also individual entrepreneurs.   The Regulation sets out several key requirements for courier services in the field of ecommerce:   Mandatory ordering through the IS of the e-commerce operator. Informing the consumer of the delivery status and the expected arrival time of the courier. In particular, the terms of the delivery service (timeframes, price, methods, delivery area, etc.) must be clearly communicated to the consumer at the time of placing the order. Adherence to the principles of reliability, safety, and timeliness in the provision of delivery services. Establishment of a system for receiving and addressing consumer feedback (complaints, suggestions, etc.) related to the quality of delivery services.   When delivering food products, service providers must comply with special sanitary and hygienic standards, including the use of thermal containers.   When delivering the following food products, their separate transportation must be ensured (in separate thermal containers (thermal bags) using compartments or thermal insulation dividers) to prevent direct contact of: − raw and cooked (finished) products, − chilled, frozen, and hot foods, − food and non-food items, − products with strong odors and other goods.   In addition, the Regulation outlines the rights and responsibilities of delivery service operators, emphasizing their obligations towards couriers. The document also establishes the rights and duties of couriers in relation to both operators and consumers. These include informing the delivery service operator, meeting delivery deadlines, ensuring non-disclosure of customers’ personal data, and exercising care in handling the delivered goods.   It is noted that couriers can accept cash payments from customers for goods provided that it is stipulated in the contract with the seller or e-commerce operator. When accepting payments, couriers must comply with the requirements of applicable law, including the mandatory use of cash registers or the issuance of a receipt in either electronic or paper form.   It is important to note that the Regulation does not apply to public procurement or to transactions on the stock exchange governed by separate legislative acts.   The Regulation applies to the delivery of medicines only to the extent that it does not contradict the provisions of the Regulation on the Procedure for the Retail Sale of Medicines and Medical Products approved by Resolution of the Cabinet of Ministers of the Republic of Uzbekistan, dated April 6, 2017, No. 185 (hereinafter referred to as the "Regulation on the Retail Sale  of Medicines").   According to the Regulation on the Retail Sale of Medicines, only over the counter (OTC) medicines and medical products may be sold through e-commerce platforms within the Republic of Uzbekistan. When selling OTC medicines online, pharmacies are required to publish specific information on their websites and mobile applications, including a list of medicines and medical products subject to sale, instructions for use, prices, and information on available analogues.   In addition, special transportation conditions must be followed during the delivery of medicines. Specifically, the delivery vehicle must be technically sound and kept in proper cleanliness. During transportation, established conditions for temperature, humidity, and air circulation in the storage chamber must be strictly maintained to preserve the quality and safety of the medicines.   The present Regulation came into effect on June 21, 2025, and from that date shall apply to the activities of courier services providing delivery in the field of e-commerce.     Contacts: Zafar Vakhidov Partner, Vakhidov & Partners Uzbekistan / Kazakhstan [email protected]           Kamila Sharipova Senior Associate, Vakhidov & Partners Uzbekistan      [email protected]