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Trademark Law

Trademark Enforcement Patterns in Uzbekistan

Over the past years, Uzbekistan has undergone dynamic transformations in the field of intellectual property, with trademark protection emerging as one of the most actively reformed and practically enforced areas. The country has prioritized modernization of its trademark system, strengthened IP governance, and expanded enforcement capacity across administrative, customs and criminal frameworks. These reforms reflect a broader policy shift toward strengthening legal certainty, improving investment attractiveness and aligning national regulation with international standards, including in the context of Uzbekistan’s ongoing accession to the World Trade Organization. Reforms took place as well in regard to institutional aspects – Ministry of Justice now plays a decisive role not only in trademark examination but also in supervision, investigations and enforcement actions. Additionally, digitalization has played a crucial enabling role. The transition to fully digital procedures – online filing systems, electronic fee payments and fully digital trademark certificates with QR verification, has significantly streamlined user experience and reduced procedural barriers. These reforms have coincided with a sharp increase in trademark filings, particularly by foreign rights holders, who now account for a substantial share of applications. For trademark owners, this shift signals that Uzbekistan is no longer merely a registration jurisdiction, but an enforcement-ready market, where proactive planning and structured protection strategies are increasingly essential. Role of the Ministry of Justice One of the most practically significant developments in Uzbekistan’s trademark landscape has been the institutional and functional empowerment of the Ministry of Justice. Beyond its traditional role in trademark examination and trademark registry maintenance, the Ministry has been granted independent supervisory and enforcement authority within the scope of intellectual property protection. The Ministry is now vested with independent authority to identify trademark infringements, request and review documentation, conduct on-site inspections and seize (arrest) counterfeit goods, packaging, labels and related materials.[1] Importantly, inspections may also be initiated upon request of the rights holder, which provides brand owners with a direct administrative enforcement channel.[2] In practice, the Ministry increasingly operates as a results-oriented enforcement authority, rather than a purely regulatory institution. Enforcement efforts focus not only on individual acts of infringement but also on broader counterfeit distribution networks, particularly in sectors where violations are systematic. The ability to act independently, without procedural delays caused by inter-agency approvals, has significantly improved enforcement speed and effectiveness. For trademark owners, this shift has important strategic implications. Effective protection increasingly depends on the ability to engage with the Ministry in a timely and structured manner. Rights holders who are prepared to submit clear evidence, articulate enforcement requests and coordinate follow-up actions are more likely to achieve tangible outcomes, including seizure and removal of infringing goods. Core Trademark Enforcement Tools Uzbek trademark law provides rights holders with a broad range of enforcement mechanisms. However, enforcement practice demonstrates that the effectiveness of these tools depends less on their formal availability and more on how they are combined and sequenced in practice. Cease-and-Desist Measures In many cases, infringement is addressed at an early stage through administrative measures, including warnings, orders to cease unlawful use, and seizure of infringing goods. These measures are particularly effective where infringement is visible, ongoing and localized. Administrative intervention allows authorities to disrupt infringing activity swiftly and often achieves compliance without escalation. For rights holders, initiating administrative enforcement can serve as a strategic first step, particularly where the objective is rapid market correction rather than long-term litigation. Seizure and Destruction Recent legislative amendments strengthened the ability of authorities to order mandatory destruction of counterfeit goods, packaging, labels and means of production. In practice, this has become one of the most impactful enforcement tools, as it eliminates the economic incentive behind counterfeiting rather than merely imposing financial penalties. In practice, destruction orders are increasingly applied following inspections conducted by the Ministry of Justice. This measure is especially relevant in cases involving repeated infringement or organized counterfeit operations. From a strategic perspective, rights holders should prioritize remedies that result in physical removal and destruction, rather than relying solely on fines, which may be treated by infringers as a cost of doing business. Judicial Protection Court proceedings remain essential in complex disputes, particularly those involving trademark validity, non-use cancellation, contractual disputes or parallel imports. Moreover, judicial protection becomes particularly relevant when it comes to perpetrator’s unwillingness to cooperate at the negotiation stage or even after the issuance of relevant order by the Ministry of Justice. Litigation ensures compulsory compliance and legal finality. However, in practice, judicial proceedings are most effective when used as part of a broader enforcement strategy that includes administrative and customs measures, rather than as a standalone response. Statutory Compensation Article 26 of the Law “On Trademarks, Service Marks and Appellations of Origin” introduces statutory compensation as an independent form of civil liability. Instead of proving actual damages, the trademark owner may claim compensation ranging from 20 to 1,000 base calculation units, with the amount determined based on the nature of the infringement, the degree of fault and business customs. Compensation is payable regardless of whether actual losses are proven, which significantly reduces evidentiary burdens. Courts may determine the amount if the parties do not reach agreement. From a strategic standpoint, statutory compensation has reshaped enforcement planning. In counterfeiting cases, infringers often operate informally, conceal financial records or lack reliable accounting documentation. Under these circumstances, proving actual damages can be impractical. Statutory compensation allows rights holders to bypass this obstacle and focus enforcement efforts on establishing the fact of infringement rather than quantifying losses. For trademark owners, the availability of statutory compensation makes civil enforcement more predictable and cost-effective, particularly when combined with administrative seizures and destruction of infringing goods. Criminal Liability for Trademark Infringement In 2025, Uzbekistan introduced criminal liability for serious trademark infringements, including counterfeiting and repeated violations causing substantial harm.[3] Sanctions include fines ranging from 50 to 150 of the base calculation units, correctional labor or liberty restriction for up to 3 years. Criminal enforcement is primarily applied in cases involving organized counterfeiting, large-scale distribution networks and repeated offenders. These amendments represent not only a strengthening of national enforcement but also a key step toward compliance with the TRIPS Agreement – a prerequisite for Uzbekistan’s accession to the World Trade Organization (WTO). Namely, TRIPS Agreement mandates criminal liability for deliberate trademark infringement on a commercial scale.[4] Criminal enforcement is not intended for routine disputes. In practice, it is applied primarily in cases involving organized counterfeit operations, large-scale distribution networks and repeat offenders. However, the possibility of criminal liability introduces a powerful deterrent effect and provides rights holders with additional leverage in negotiations and enforcement actions. For brand owners, while not appropriate in every case, its availability strengthens the overall enforcement framework and increases the cost of non-compliance for infringers. Border Measures To reinforce protection against counterfeit imports, trademark owners may record their registered marks in the Customs Register maintained by the State Customs Committee of Uzbekistan. Сustoms recordal serves as a preventive enforcement tool, enabling the interception of infringing goods at the border, thereby addressing trademark violations at the earliest possible stage. Under Uzbek law, customs authorities are vested with “ex officio” powers, allowing them to independently suspend the release of goods suspected of IP infringement for up to ten working days without a prior complaint from the rights holder. Where a recorded trademark is involved, customs authorities are required to notify the trademark owner within one business day, enabling the prompt initiation of legal or administrative action. In the absence of any response, the authorities may act accordingly even without a prior request from the rights holder and forbid the importation.[5] These border measures are particularly effective in sectors highly exposed to counterfeiting risks, including pharmaceuticals, electronics, cosmetics, apparel and consumer goods. For rights holders operating in these sectors, customs recordal is not merely a supplementary measure but a core element of risk management. Strategically, customs enforcement allows brand owners to prevent infringing goods from entering the market rather than attempting to remove them after distribution has occurred. Parallel Imports Currently, the legislation of the Republic of Uzbekistan does not provide for direct regulation of parallel imports. Instead, since 2017, the country has applied a trademark rights exhaustion regime[6], meaning that genuine goods placed on the market by the trademark owner, or with their consent, may be imported into the country without authorization from the rights holder. However, the legislation does not clearly define whether exhaustion is national or international, leaving room for interpretation. Courts have occasionally accepted arguments favoring international exhaustion, while competition authorities have tended to apply a more restrictive approach in favor of national principle. This ambiguity creates uncertainty for trademark owners seeking to control distribution channels. In practice, trademark owners should anticipate limited control over downstream distribution and adopt a risk-based approach. Contractual safeguards, customs monitoring, conclusion of distribution agreements and market surveillance play a critical role in mitigating the impact of parallel imports. While complete exclusion of parallel imports may be difficult, strategic planning can reduce their disruptive effects. Unfair Competition In practice, the most common forms of trademark-related unfair competition in Uzbekistan are manifest through the use of similar trade dress or confusingly similar designations, creating a likelihood of consumer confusion. Until October 2023, such conduct could be addressed under the Law “On Competition”, which expressly prohibited IP-related unfair acts and empowered the Antimonopoly Committee to intervene. Following legislative reform, all IP-related unfair competition provisions were removed and thus, newly formed Competition Promotion and Consumer Protection Committee (former Antimonopoly Committee) no longer has jurisdiction over IP matters.[7] As a result, trademark disputes, previously addressed through administrative competition proceedings, must now be pursued exclusively through trademark law mechanisms and the courts. At the same time, despite the ongoing reforms, the Uzbek market continues to face structural challenges associated with the circulation of counterfeit goods and the persistence of bad-faith trademark filings, commonly referred to as trademark squatting. In practice, this involves attempts to register well-known or internationally recognized brands without authorization, with the aim of exploiting their reputation or leveraging registration for commercial or strategic advantage. Therefore, the removal of IP-related unfair competition provisions from competition law may amplify these risks, as enforcement practice adjusts to the new legal framework and trademark disputes are fully absorbed into civil and administrative IP mechanisms. For manufacturers and service providers, this transitional phase underscores the importance of proactive trademark portfolio management, including early filings, systematic monitoring of new applications, and timely opposition or invalidation actions to mitigate the risks associated with bad-faith registrations. Conclusion Uzbekistan has reached a stage where trademark protection is increasingly practical rather than purely formal. Enforcement mechanisms are now more centralized and coordinated, combining civil, administrative, criminal and customs tools. While transitional challenges remain, particularly in the areas of unfair competition and parallel imports, the overall direction of regulatory and enforcement practice is becoming more consistent and predictable. This trajectory is further reinforced by Uzbekistan’s ongoing WTO accession process, which continues to drive legislative alignment with international intellectual property standards. For trademark owners, Uzbekistan represents a jurisdiction in which enforcement is increasingly viable, provided that protection strategies are planned in advance and actively managed. Effective brand protection depends less on reactive litigation and more on early registration, systematic monitoring, use of customs mechanisms and coordinated engagement with enforcement authorities. Rights holders prepared to adopt a strategic approach can reasonably expect enforceable and sustainable outcomes in the Uzbek market.   Authors: - Jamshid Agzamkhadjaev (Managing Partner, Settle Law Firm) - Saida Djunaydullaeva (Junior Associate, Settle Law Firm)   References: [1] President of the Republic of Uzbekistan, Decree No UP-80 (24 May 2024). [2] Law of the Republic of Uzbekistan No 267-II (30 August 2001) art 37¹. [3] Law of the Republic of Uzbekistan No ZURK-1080 (8 August 2025). [4] Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS Agreement) (adopted 15 April 1994, entered into force 1 January 1995) art 61. [5] Law of the Republic of Uzbekistan «On Amendments and Additions to the Customs Code of the Republic of Uzbekistan Aimed at Further Improvement of Customs Procedures» No. ZRU-913 (27 February 2024) art 382¹ para 1. [6] Civil Code of the Republic of Uzbekistan, Part Two, adopted on 1 March 1997, Art. 11071. [7] President of the Republic of Uzbekistan, Decree No UP-108 (6 July 2023).
SETTLE law firm - December 29 2025
Press Releases

Regulation of Clinical Trials in the Republic of Uzbekistan

What is a clinical trial? Clinical trials ("CT") of pharmacological products ("PP") or medicinal products ("MP") are defined as studies involving human subjects conducted to investigate the pharmacological properties, side effects, and interactions with other MP in order to determine the safety and efficiency of MP/PP. What types of CTs can be conducted in the Republic of Uzbekistan ("Uzbekistan")?  CT of MP/PP may be conducted in a single medical and preventive institution ("Clinical Base") or according to a single protocol in the form of a multicenter (interventional) CT in more than one Clinical Base. In Uzbekistan, the main legal acts regulating CTs are: Law of Uzbekistan "On Medicines and Pharmaceutical Activities" dated January 4, 2016, No. 399 It regulates the basic requirements for CT. Resolution of the Cabinet of Ministers of Uzbekistan "On Measures to Develop CTs of MPs and Organize their Conduct in Accordance with International Standards" dated April 14, 2022, No. 181 The resolution defines the legal basis for the organization of the State Enterprise "Center for CT Development" ("Center")and describes its main responsibilities. Order of the Minister of Health of Uzbekistan on the Approval of the Regulation "On the Procedure for Conducting CT of MP/PP" dated June 5, 2023, No. 3439 It defines the legal basis for regulating and conducting CT of MP/PP within the framework of state registration of MP/PP. It should be noted that, in the absence of a regulatory act governing the conduct of independent CT, this ministerial order also applies to the independent CTs, carried out outside the framework of state registration of MP/PP. Key Regulatory Bodies Ministry of Health of Uzbekistan ("MH") approves the CT of MP/PP on humans, approves the procedure for conducting CT of MP/PP and the list of Clinical Bases where CT are conducted. Pharmaceutical Industry Development Agency organizes the examination of the results of preclinical trials and CT of MP/PP and medical devices ("MD"), ensures the state registration, quality control, standardization, and certification of MP/PP, MD, and medical equipment. organization of CT of MP/PP in accordance with the requirements of Good Clinical Practice (GCP), determination of the pharmacological bioequivalence of generic MP to original MP, conducting pharmacokinetic studies of MP/PP in CT subjects, improving the qualifications of medical workers in the field of conducting CT, International cooperation in the field of Good Clinical Practice (GCP). Pharmacology Committee ("PC") at the Center The structural subdivision of the Center responsible for issues related to CT of MP/PP. Clinical Base  Medical and preventive institutions that can perform CT of MP/PP  included in the list approved by the MH. Ethics Committee (the "Committee") A permanent collegial body operating on a voluntary basis, approved by the MH and consisting of representatives of medical and research organizations, higher education institutions, the media, non-governmental non-profit organizations, and other civil society institutions. The Committee conducts ethical reviews of the ethical validity of CT. Board of Experts (the "Board") decides whether to approve or reject the use of MP/PP in medical practice. Is notification/permission required to conduct CT in Uzbekistan? As part of the state registration of MP/PP, based on the recommendation of the PC, the Board shall, within one working day of receiving the relevant recommendation, decide on the conduct of a CT. Within one working day of the decision being made by the Board of PC, the applicant will receive a notification via the electronic system indicating the possibility of conducting a CT. With regard to conducting independent CT of MP/PP on humans in Uzbekistan, it is mandatory to obtain permission from the MH. However, there are no specific regulations or procedures for obtaining such permission in the current legislation. MH, which reviews the application in accordance with international ICH GCP standards for issuing a CT permit. After approval by the MH, the applicant submits the documents to the Center, where the request is reviewed in accordance with internal rules. The procedure applies to applications from individuals and legal entities and does not constitute a procedure for conducting independent CT due to the lack of legal grounds. What are the requirements for participating in the CT? Obtaining a written consent:A subject may be included in a CT only if he or she or his or her legal representative has received information regarding the nature and possible consequences of the CT, the properties of the MP/PP, its expected efficacy, and the degree of risk, and has given his or her Consent to participate in the CT. Restrictions on participation in CTs for certain categories of persons. In cases where the CT is conducted with the participation of a minor or incapacitated person, the consent of their legal representative must be obtained prior to the commencement of the CT. Requirements for Clinical Bases Conducting CT. The Clinical Base included in the list approved by the MH must have a legal address, seal, and bank account with the Republic of Uzbekistan. Material resources (laboratory and diagnostic equipment, instruments, tools, etc.) that enable the effectiveness and safety of the tested product to be assessed in accordance with international standards. High scientific qualifications of the Clinical Base's staff. Existence of an ethics committee. Result of Conducting CT Upon completion of a CT, an applicant is issued individual registration forms and CT’s subject consent forms signed by the CT director and research physicians. Based on the results of the CT, a CT report is compiled. The CT report is approved by the director of the Clinical Base and is submitted to the applicant. The CT report for state registration of MP/PP submitted by the applicant is sent for final review by the PC within 15 days. The review is conducted to verify that the CTs conducted comply with the approved protocol. If there are no discrepancies between the report and the CT protocol, the results of the final review are sent to the Board. With regard to an independent CT, in the absence of a separate procedure after completing the CT, the Center issues a report to the applicant based on the Center's internal rules, similar to the procedure described above. Next, the PC conducts a final review of the CT in accordance with the approved CT protocol.
Vakhidov & Partners - December 29 2025
Press Releases

Regulation of Clinical Trials in the Republic of Kazakhstan

What is a clinical trial? A clinical trial (“CT”) is a study involving human subjects, conducted to identify or confirm the safety and effectiveness of means, methods, and technologies for the prevention, diagnosis, and treatment of diseases. What types of CTs are there? A non-interventional CT is a study which is conducted after the state registration of a medicine or medical device (“MD”) and is prescribed as part of medical practice. An interventional trial is a study involving a human subject in which a researcher-physician assigns a specific intervention to the subjects based on an interventional CT protocol which complies with the CT procedure. Is a notification/permission required to conduct clinical trials? To conduct an interventional CT of a medicine, it is necessary to obtain a permission from the Committee for Medical and Pharmaceutical Control of the Ministry of Healthcare of the Republic of Kazakhstan. Before obtaining the permission, it is necessary to obtain a conclusion on the results of the examination of the CT materials from the National Center for Expertise of Medicines and MDs, as well as a conclusion on the results of the bioethical examination of the CT materials from the Central or Local Bioethics Commission. For non-interventional CT notification is required. For non-interventional CT, it is necessary to obtain a conclusion based on the results of a bioethical examination of the CT materials from the Central or Local Bioethics Commission. In the Republic of Kazakhstan (“RK”), the main legal acts regulating CT are: The Code of the RK dated July 7, 2020 No. 360-VI "On Public Health and the Healthcare System" Defines the legal bases for regulating and conducting CT of Medicines, MDs, and clinical laboratory tests of MDs for diagnostics outside a living organism (in vitro). Rules of Good Clinical Practice of the Eurasian Economic Union, approved by the Decision of the Council of the Eurasian Economic Commission of November 3, 2016 No. 79 Establish international ethical and scientific standards for planning and conducting studies involving human subjects, as well as for the documentation and presentation of the results of these studies. The Standard of Good Clinical Practice (GCP), approved by the Order of the acting Minister of Healthcare of the RK dated February 4, 2021, No. ҚР ДСМ-15) Establishes rules for conducting studies involving human subjects, as well as for the documentation and presentation of the results of these studies. ISO 14155:2014, Recommendation of the Board of the Eurasian Economic Commission of September 4, 2017, No. 17: CT of MDs involving human subjects. Good clinical practice. Establishes provisions for good clinical practice for the planning, conduct, documentation, and reporting of results of CT involving human subjects to evaluate the safety or performance of MDs. Rules for Сonducting СT of Medicines and MDs for In Vitro Diagnostics and Requirements for Clinical Sites and for the Provision of the Public Service "Issuance of Permission to Conduct CT and/or Testing of Pharmacological and Medicinal Products, MDs, approved by order of the Minister of Healthcare of the RK dated December 11, 2020 No. ҚР ДСМ-248/2020 Establish the procedure for conducting CTs of Medicines and MDs, clinical laboratory tests of MDs for diagnostics outside a living organism (in vitro) and requirements for clinical bases. Key regulatory bodies Ministry of Healthcare of the RK The Committee for Medical and Pharmaceutical Control of the Ministry of Healthcare of the RK Issues permission to conduct CT and/or testing of pharmacological and medicinal products, MDs; Conducts CT inspections. National Center for Expertise of Medicines and MDs Conducts an examination of CT materials and issues a conclusion on the conduct of CT. Central Commission on Bioethics Conducts a bioethical examination of CT materials and issues opinions on the conduct of interventional CT of foreign-produced medicines and MDs, as well as interventional and non-interventional CTs of Medicines and MDs conducted in two or more research centers located in the territory of the RK. Local Bioethics Commission Conducts a bioethical examination of materials of single-center interventional and non-interventional CTs, with the exception of cases of interventional CTs of Medicines and MDs produced outside the RK. What are the requirements for clinical sites? The requirements for clinical sites: availability of a license to carry out medical activities; availability of standard operating procedures for conducting CTs; availability of clinical, instrumental and laboratory equipment for conducting CTs or availability of contracts with contractors for the provision of specialized clinical, instrumental, laboratory and auxiliary services for conducting CTs (in the absence of the necessary equipment); availability of personnel with medical education and a GCP training document; availability of conditions for intensive care and resuscitation (if required by protocol); availability of a document establishing the procedure for working with confidential information. GCP and ISO14155:2014 standards set more detailed requirements for clinical sites. Are there any CT inspections in the RK? Inspections are carried out by the Committee for Medical and Pharmaceutical Control of the Ministry of Healthcare of the RK in accordance with the Rules for Conducting Pharmaceutical Inspections on Good Pharmaceutical Practices, approved by Order No. ҚР ДСМ-9 of the Minister of Healthcare of the RK dated January 27, 2021. The objectives of the inspection are the following: assessment of compliance with GCP and ISO 14155:2014 standards; confirmation of compliance of the CT with the approved CT protocol; confirmation of the reliability of the data obtained as a result of CTs; investigation of complaints (signals) received with regard to the CT, as well as upon receipt of additional information about the risk associated with conducting the CT; protection of the rights, health and well-being of the subjects of CTs. Inspection is carried out at any stage of the CT in a planned (primary) or unscheduled manner (including in connection with a threat or harm to the life or health of trial subjects). The Ministry of Healthcare of the RK, based on the inspection data, makes a decision on: termination of CT; recognize the results of the CT. What are the requirements for participation in the CT? The need to obtain informed consent:. Before inclusion in the CT, the trial subject or their legal representative shall receive the information about the planned CT, on the basis of which the trial subject or their legal representative signs the informed consent for voluntary participation in the trial. Restrictions on participation in CTs for certain categories of persons: CTs of medicines and MDs on minors, pregnant women, incapacitated individuals, students, pensioners, and those requiring assistance are conducted only to study the therapeutic effect and with the consent of a relative, guardian, or parent. Prohibition of participation in CTs for certain categories of persons: interventional CTs on military, law enforcement and special government agencies’ personnel, employees of medical organizations where biomedical research is conducted, and persons held in penal institutions are prohibited. What constitutes the result of the CT? The result of the CT is the final report on the conducted CT of medicines and MDs, regardless of whether the trial was completed or terminated early. No later than 1 year after the full completion of the CT (in case of international CTs, after the completion of the CTs in all countries), the sponsor provides brief information about the CT to the Committee for Medical and Pharmaceutical Control of the Ministry of Healthcare of the RK and the Central Bioethics Commission which issued the permission to conduct the CT. The sponsor and the investigator archive the materials (documents) of the CTs and ensure their safety for 25 years from the date of completion of the CT. As of the publication date of this alert, the draft regulations on CT are under public discussion; therefore, further amendments may be introduced.  
Vakhidov & Partners - December 29 2025
Press Releases

Commerce Legislation News Uzbekistan – November  2025 The regulatory framework governing trade activities in the Republic of Uzbekistan (hereinafter referred to as “Uzbekistan”) has undergone significant amendments designed to strengthen consumer protection mechanisms. Below is an overview of the key developments. The Government has approved new regulations governing promotional campaigns and discounts in retail trade. By Resolution of the Cabinet of Ministers of Uzbekistan No. 662 dated October 21, 2025 (hereinafter referred to as the “Resolution No. 662”), amendments and additions have been introduced to a number of regulatory acts, including the Rules of Retail Trade of Uzbekistan approved by Resolution No. 75 dated February 13, 2003 (hereinafter referred to as the “Trade Rules”). The draft of the new procedure for regulating promotional campaigns and discounts in retail trade was initiated by the Competition Promotion and Consumer Protection Committee (hereinafter referred to as the “Competition Committee”) in July 2025. Under the amendments, Clause 3 of the Trade Rules is supplemented with the following new definitions: Promotional Campaign –  advertising in the form of an event, contest, or game that encourages consumers to take certain actions, including participation conditioned upon receiving the advertised product; Price List – information indicating the final price set for a unit of goods or a specific quantity of goods, typically offered to the consumer without any conditions, in a single copy and clearly stated; Discount Price – a price at which the cost of goods is reduced by a certain percentage or amount from its pre-discount price; Pre-Discount Price – the lowest price set for a unit of goods, typically offered to the consumer within 30 days prior to the announcement of the discount price, which must be confirmed by the seller. In addition, the Trade Rules have been supplemented with a new Chapter XVII⁴ governing the regulation of promotional campaigns and discounts. Under the new requirements, when applying a discount to the price of goods, the seller must: Indicate the pre-discount price (except for agricultural products). Failure to do so will be deemed a price reduction rather than a discount; Avoid artificially inflating prices prior to announcing discounts; Maintain records of goods and prices, including price history for the last 30 days, and provide this information to consumers upon request. Furthermore, when announcing a promotional campaign, the seller is required to: Clearly and transparently communicate its terms to consumers, including duration, list of goods, quantities, and purchase conditions; Refrain from altering the terms of the campaign after its announcement or providing misleading information; Ensure actual compliance with all declared discounts, bonuses, and benefits under the campaign; Maintain sufficient stock of goods included in the campaign for its entire duration. In addition, retailers should also take into account the following requirements: When conducting a promotional campaign in the form of a mass event, the established procedures must be observed, and prior authorization must be obtained from the internal affairs authorities; When processing personal data of campaign participants, compliance with personal data legislation is mandatory, and consumers must be informed of the purposes and conditions of data processing. The Government has approved regulations on prescription medicines and abolished price controls for over-the-counter medicines and medical devices. The Resolution No. 662 also introduces amendments to Cabinet of Ministers Resolution No. 185 dated April 6, 2017, “On Measures to Implement the Law of the Republic of Uzbekistan dated January 4, 2016, No. 399 ‘On Amendments and Additions to the Law of the Republic of Uzbekistan ‘On Medicinal Products and Pharmaceutical Activity’” (hereinafter referred to as the “Resolution No. 185”). Under the amendments, the scope of price regulation has been narrowed. Price controls now apply exclusively to prescription medicines in both wholesale and retail sales. All previous references to “medicines and medical devices” have been replaced with “prescription medicines.” Accordingly, references to medical devices have been removed, and the mechanism for determining prices for imported prescription medicines has been clarified. Restrictions on trade mark-ups for Prescription Medicines remain in force. In addition, wholesale and retail prices for Prescription Medicines must not exceed the established reference price limits. Another significant change is the transfer of control functions for compliance with legislation governing wholesale and retail sales of medicines from the previously authorized body, the Agency for the Development of the Pharmaceutical Industry under the Ministry of Health of the Republic of Uzbekistan, to the state institution “Center for Pharmaceutical Product Safety.” The President introduces measures to strengthen liability for selling expired or improperly labeled food products On October 6, 2025, the President of the Republic of Uzbekistan, Shavkat Mirziyoyev, signed Resolution No. 296 (hereinafter referred to as the “Resolution No. 296”), which provides for enhanced control over the quality and safety of food products and the implementation of modern mechanisms for consumer protection. Under the Resolution No.296, starting March 1, 2026, the sale of expired products will be restricted through the digital labeling system “Asl Belgisi.” Cash register systems will not allow receipts to be issued for products past their expiration date. Currently, labeling requirements apply to tobacco and alcohol products, medicines, water and beverages, mineral fertilizers and chemicals, among others. In addition, from October 15, 2025, to January 1, 2027, a pilot procedure will be introduced under which consumer complaints and test purchases will be handled by non-governmental non-profit organizations (hereinafter referred to as “NGOs”). Employees of such NGOs must hold a special certificate confirming completion of training courses at the Center for Research on Competition Policy and Consumer Rights under the Competition Committee. The Resolution No.296 also approves the Competition Committee’s proposal to strengthen administrative liability for the sale of food products: with expired shelf life; without indication of the production date and/or expiration date, where such labeling is mandatory. Previously, Article 178 of the Administrative Liability Code of Uzbekistan provided for fines ranging from 3 to 10 BRV (approximately UZS 1.2–4.2 million) for individuals and 7 to 10 BRV (approximately UZS 2.8–4.2 million) for officials. Following the amendments, the upper limit of the fine for both individuals and officials will be 30 BRV (approximately UZS 12.3 million). To facilitate the submission of consumer complaints and enable prompt responses, the Competition Committee will launch the “Consumer Complaint” information system on December 1, 2025. This platform will allow monitoring of complaint handling at all stages. The system will be integrated with the personal account of the Tax Committee, enabling entrepreneurs to receive real-time notifications of consumer complaints. Under the new procedure: Initial review of complaints must be carried out by entrepreneurs within 10 calendar days, under the supervision of the Competition Committee; If the entrepreneur fails to remedy the violation or provide a reasoned response, the complainant may: submit the complaint to the Competition Committee; or contact a consumer protection organization. If the entrepreneur does not eliminate the violation within 10 days, the organization may, through the system, escalate the complaint to the Competition Committee or file a claim in court.
Vakhidov & Partners - December 10 2025