Parallel Imports in the New EnvironmentIn response to sanctions pressure, the Government of the Russian Federation decided to legalise
parallel imports for certain categories of goods.[3] The relevant list was approved by Order No.
1532 of the Ministry of Industry and Trade of Russia dated 19 April 2022
Accordingly, original goods included in the approved list may currently be imported into Russia
without the consent of the rights holder, including through channels other than the official
distribution network.
It should be emphasised that the legalisation of parallel imports does not legalise counterfeit
goods or reduce product quality requirements.
The Ministry of Industry and Trade has also stressed that products imported into Russia must
comply with all applicable quality requirements and standards and must be accompanied by the
necessary permits and authorisations.[4]
The Ministry’s Order entered into force on 7 May 2022 It is still too early to draw conclusions
about its application by the customs authorities. In the absence of official guidance, only
preliminary observations can be made.
The approved list includes several categories relevant to the children’s products industry.
Examples include goods classified under EAEU Commodity Classification Code Group 95,
which covers toys, games, sports equipment and their parts and accessories, and Groups 61 and
62, which cover clothing and clothing accessories.
However, the approach of the customs authorities may differ depending on the category:
- EAEU Commodity Classification Codes 61 and 62, covering clothing, are listed without
reference to specific trade marks. It may therefore be concluded that the importation of
any goods falling within the relevant codes is permitted.
- Under EAEU Commodity Classification Group 95, covering toys, the list includes Code
9504 50 000 9 for video game consoles and the specific trade marks Xbox, PlayStation
and Nintendo. It may therefore currently be assumed that parallel imports are permitted
only for goods bearing those trade marks.