Parallel import means importing genuine goods without separate consent from the rights holder for that import. Russia’s special mechanism does not cover all foreign goods: the Ministry of Industry and Trade list must be checked, along with the condition that the goods were placed on the market outside Russia by the rights holder or with its consent. The mechanism does not legalise counterfeits. Ministry’s GISP: mechanism and conditions, Order No. 2701 in the Ministry of Justice register.
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The practical answer for importers is to match the exact model, its EAEU commodity code, trademark, exclusions in the relevant entry and the applicable version of that entry before paying. Then check permits, labelling, route restrictions and customs payments separately. Finding a brand in a news summary is not a substitute for these checks.
The difference is not the country of dispatch or the word “genuine” on an invoice. The special mechanism depends on the goods’ origin and their lawful placement on the market abroad. Goods of unknown origin bearing someone else’s trademark do not become eligible merely because that brand appears in the list. Order No. 2701 expressly requires placement on the market by the rights holder or with its consent. Ministry of Justice register: Order No. 2701.
It is therefore useful to request purchase records, manufacturer details, item and serial numbers, photographs of the goods and packaging, and an explanation of the supply chain where necessary. This is a practical review package, not a universal statutory “certificate of authenticity”. An invoice or photograph alone does not provide conclusive evidence that the entire shipment is genuine.
Authenticity and the right to import are also separate questions. Even genuine goods may fail to meet the special mechanism’s conditions. In that case, the rights holder’s consent, exhaustion of rights and other applicable grounds require separate assessment; genuine goods must not automatically be treated as eligible for import.
Exhaustion of an exclusive right means that, after particular goods have been placed on the market in the circumstances prescribed by law, the rights holder cannot invoke that right to prohibit certain subsequent dealings in those goods. Article 1487 of the Russian Civil Code concerns trademarks; Article 1359(6) addresses the corresponding circumstances for inventions, utility models and industrial designs. These concern different intellectual property rights and are not interchangeable provisions. Civil Code, Part Four, on Rospatent’s website.
For trademarks, the EAEU regional principle must also be considered: lawful placement on the market in a member state by the rights holder or with its consent matters. Mere transit through an EAEU country does not establish that condition. The basis is paragraph 16 of Annex 26 to the EAEU Treaty. Eurasian Economic Commission: explanation of exhaustion.
Russia’s special mechanism originated in 2022: Article 18(1)(13) of Federal Law No. 46-FZ of 8 March 2022 authorised the designation of relevant goods, Government Resolution No. 506 of 29 March 2022 established the list mechanism, and Federal Law No. 213-FZ of 28 June 2022 added a provision to Article 18 concerning intellectual property used in such goods. Article 18 of Law No. 46-FZ — legislative text, GISP: Resolution No. 506 and supporting documents.
The Government’s relevant powers were continued for 2026 by Federal Law No. 463-FZ of 15 December 2025: it added Article 18(1.1) and took effect on 1 January 2026. This is neither permission to import any brand nor the abolition of all exclusive rights. Law No. 463-FZ — text, Article 2 on commencement.
The working basis is Ministry of Industry and Trade Order No. 2701 of 21 July 2023, with the applicable amendments. Order No. 4769 of 26 September 2025, registered on 26 November 2025 under No. 84297, changed a number of entries. It sets different commencement periods: some amendments apply from the day after official publication, others after six months. The deferred provisions apply from 27 May 2026. That date must not be applied to every amendment in the order. Order No. 4769 in the Ministry of Justice register, text of paragraphs 2–3.
For each shipment, consult the version applicable to the relevant operation, not a table saved the previous year. The contract or advance-payment date alone does not establish that an earlier entry can govern a future import. If the list changes during transport, transitional provisions need separate review.
| How an entry is framed | What to check |
|---|---|
| Commodity code with named trademarks | The goods must match the code and the trademark specified in that entry |
| Commodity code with trademark exclusions | Check the code and whether the particular goods fall within an exclusion |
| Commodity code without named brands | Check the code’s scope and all other conditions of the entry; the list does not remove other import requirements |
This is a reading guide, not a standalone list of eligible goods. The Ministry describes these three patterns in GISP; the final assessment must use the full relevant entry, including notes and limitations. GISP: three types of permission.
A supplier’s suggested code should be checked against the product’s characteristics. A spare part, finished device and set may fall under different headings; eligibility in one product category does not extend to the brand’s entire range. See how to determine an EAEU commodity code.
Intellectual property review is only one part of shipment preparation. The EAEU Customs Code separately regulates compliance with prohibitions and restrictions and customs declaration, notably in Articles 7 and 104. A basis for import without rights-holder consent does not replace those requirements. EAEU Customs Code.
Check separately:
Russian permission concerning intellectual property is not export authorisation from another country and does not disapply applicable sanctions restrictions. Suppliers, products, end users, carriers and banks require separate screening. Altering product descriptions, destinations or parties in the documents cannot substitute for that review.
The following is a working file for preliminary assessment; the exact contents depend on the goods and transaction.
| Area | What to prepare and why |
|---|---|
| Identification | Model, item number, manufacturer, trademark, technical description, photographs and serial numbers where available — to match the goods with their records |
| Commercial chain | Contract, specification, invoice, seller details and available records of earlier purchases — to assess the transaction and the shipment’s origin |
| Legal basis | EAEU commodity code, relevant list entry, applicable version and review date — to record a reproducible reason for considering the special mechanism |
| Compliance and restrictions | Technical-regulation, labelling and permit documents where required for the specific products |
| Logistics and value | Route, delivery terms, transport documents, freight and insurance costs — for clearance and cost assessment |
Consider arranging payment terms so that critical information is available before irreversible expenditure. Discuss authenticity, consistency between models and documents, responsibility for inaccurate information and what happens if lawful delivery becomes impossible in the supplier contract.
A company plans to buy equipment and consumables under the fictional brand “Brand A”. For the equipment, the applicable list entry contains the relevant code and that trademark. The consumables have a different code, and their entry does not provide the same basis.
The preliminary conclusion is that the assessment for the equipment cannot be extended to the consumables. For the first item, authenticity, permits and the legality of the entire transaction still need checking. For the second, another legal basis must be established or the purchase reconsidered. This is a teaching example, not an opinion on a real brand or product.
A working record, not permission to import.
| Field | What to record |
|---|---|
| Product and model | Description from the supplier's documents |
| Proposed TN VED code | Value and basis; mark separately if unconfirmed |
| Trademark | Wording or marking shown in documents and on the product |
| Entry being checked | List entry and document version |
| Source | Official document/register and link |
| Check date | Actual date the source was consulted |
| Confirmed information | The specific fact established |
| Unresolved information | Open question and document needed |
A completed record does not replace an assessment of how the rules apply to the particular product and transaction.
No. The particular goods must match the relevant entry, and the code, exclusions and applicable version must be checked. Different product categories under one brand may have different treatment.
The absence of a name is not always decisive: an entry may use a code without specifying brands. If the special mechanism is unavailable, rights-holder consent and other lawful grounds need separate assessment; permission must not be assumed.
No. Intermediary status itself proves nothing. Verifiable information about the shipment and its origin is needed. The special mechanism does not cover counterfeits.
Where required for the products and operation, parallel-import status alone does not waive them. Any exemption or special procedure must be checked separately under the applicable rule.
The mechanism itself provides no such exemption. Payments and any relief are determined separately by the goods, customs procedure and applicable rules; see the customs valuation and payments guide.
Before shipment or proceeding with clearance, recheck the relevant entry, the amendment’s effective date and any transitional provisions. Payment does not guarantee that earlier treatment remains available.
Record which product was checked, the sources used, the actual check date and the questions still open. For preparing a consignment for customs clearance, describe the model, available documents and shipment plan. Legal issues concerning the transaction are considered separately through legal support.
Discuss the route and delivery through Senateks contacts as part of logistics.
This guide helps organise preliminary checks and does not replace an assessment of a particular shipment. Import eligibility depends on the documents and the requirements applicable on the relevant date.