Parallel import into Russia: what the term means

Our position on sanctions

The Russian parallel import regime is a matter of Russian intellectual property law only. It does not relax any export restriction that applies to you as a supplier. We handle only goods that are not subject to EU, UK, Swiss or US sanctions, we screen HS codes and all parties before accepting an order, and we never route goods through third countries to hide their origin or destination.

What parallel import means in plain terms

Parallel import is the import into a country of original goods without the consent of the trademark owner, while complying with all other customs and tax requirements. The key word is “original”: the goods are genuine products that were lawfully manufactured and first put on the market abroad by the brand or with its permission. This is fundamentally different from counterfeits and fakes, whose import remains illegal and is prosecuted.

The mechanism rests on a change in the principle of exhaustion of trademark rights. Until 2022 Russia applied national exhaustion: only the rights holder or its appointed official distributor could import branded goods. For certain categories of goods and brands an international principle now applies in effect — if the goods have already been lawfully sold somewhere in the world, they may be bought there and imported into Russia without the brand owner’s permission as far as Russian law is concerned.

Parallel import does not bypass customs: the goods are fully declared, duty, VAT and fees are paid, and certificates and declarations of conformity are issued. It is an ordinary declared import that differs only in that the importer has no contract with the rights holder and no official permission for that particular consignment.

The Russian legal basis

Several acts form the legal basis. The core one is Federal Law No. 46-FZ of 08.03.2022, whose Article 18(3) gave the Government the right to define a list of goods to which certain Civil Code provisions on the protection of exclusive rights do not apply. On that basis Government Decree No. 506 of 29.03.2022 authorised the Ministry of Industry and Trade (Minpromtorg) to compile and maintain the list of goods (groups of goods) admitted to parallel import.

The specific list of brands and product lines is approved by order of Minpromtorg. It is organised along two axes: EAEU HS (TN VED) codes (product categories) and specific trademarks. For some lines parallel import is allowed for all brands within the product group, for others only for brands named explicitly. Minpromtorg revises the list regularly, adding lines where shortages arise and removing brands and categories whose owners have returned to official supply or localised production.

The Civil Code also contains the importer’s legal safeguard: Article 1359(6) and Article 1487 describe the exhaustion of exclusive rights, and Decree 506 in effect removes listed goods from civil liability for import without the rights holder’s consent. Under Russian law, an importer of listed goods cannot be sued for trademark infringement merely because the brand did not give permission.

The Minpromtorg list: how it works

The list covers thousands of product lines by HS code and is updated regularly. It has traditionally included electronics and household appliances, vehicles and components, industrial equipment and machine tools, perfume and cosmetics, branded clothing and footwear, household chemicals, medical equipment, optical and measuring instruments, toys and sporting goods. Its composition is not static: some electronics lines and brands whose manufacturers resumed work with the Russian market have been removed, while other categories were added to address shortages.

Because the list changes several times a year, the current version of the Minpromtorg order must be checked for the planned date of import before a contract is signed. Whether goods are covered is determined by the HS code and the trademark together: if the brand is named in the relevant line, parallel import is allowed for it; if the line allows parallel import without restriction by brand, any original goods in that category qualify.

If a brand or category is not on the list, that does not automatically ban its import — it means the rights holder’s consent or an official supply channel is required under Russian law. Either way, being on the Russian list says nothing about whether the goods may be exported from the EU, the UK, Switzerland or the US.

What this means for you as a supplier

The Russian list only answers a question of Russian trademark law. Your own obligations are set by the export rules of your jurisdiction: EU, UK, Swiss and US sanctions and export controls prohibit the supply of many categories of goods to Russia, including luxury goods and dual-use items, regardless of how Russia treats trademarks. A product being “allowed for parallel import” in Russia never makes its export lawful.

Before we accept a shipment we therefore screen the HS codes against the applicable restrictions and check all parties to the transaction. We ship only goods that are not subject to sanctions, with the true origin, seller, buyer and destination stated in every document, and with the EX1 export declaration lodged in the EU. We do not offer routing through third countries or re-export hubs as a way round restrictions, and we decline orders for sanctioned goods.

Customs clearance and documents in Russia

Goods imported under the parallel import regime are cleared under the general rules of the EAEU Customs Code: a goods declaration (DT) is lodged, and import duty at the rate for the HS code, VAT (as a rule 22% from 2026, reduced rates for certain categories) and customs processing fees are paid. The customs value is determined by the methods of the EAEU Customs Code, most often the transaction value, and must be supported by documents.

The basic document set includes the sales contract, invoice and packing list, transport documents (CMR, bill of lading, air waybill) and documents confirming the origin and lawful acquisition of the goods from the supplier. To confirm that goods are original and were lawfully placed on the market, customs may request additional evidence of the supply chain. Goods subject to mandatory conformity assessment need EAEU certificates or declarations of conformity (EAC marking).

Mandatory Chestny Znak labelling applies to a number of categories (footwear, perfume, tyres, apparel, photographic equipment and others; the list is growing), and codes must be applied before the goods are released into circulation. For vehicles, the recycling fee and an electronic vehicle passport (EPTS) are added.

Risks on the Russian side

• ✓Removal from the Minpromtorg list by the time of actual import: the list changes, and a line allowed at the start of a project may be excluded. The current version has to be checked before every delivery.
• ✓Counterfeits or goods with fake labelling presented as parallel import: this is a direct violation, so only original goods with a verifiable supply chain can be considered.
• ✓Customs risks: customs value adjustments, disputes over the HS code, certification and labelling requirements. Careful document preparation and a realistic declared value with supporting evidence help here.
• ✓Sanctions and export control risk on the supplier’s side, which the Russian regime does not address at all — see above.

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