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).

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.

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.

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.