Responsibility for violation of the digital labeling regulations

Регина Леоненко

Product labeling is regulated at the legislative level. The main governing documents are:

Decree of the Cabinet of Ministers dated November 21, 2020 No. 737 “On the Introduction of a System of Mandatory Digital Labeling of Certain Types of Goods”;
Decree of the Cabinet of Ministers dated December 31, 2020 No. 833 “On Measures to Ensure the Phased Implementation of the System of Mandatory Digital Labeling of Certain Types of Goods” – cancels the effect of the first Decree.

Violation of the established rules and requirements is punished administratively. Liability for non-compliance with labeling rules is specified in the Decree of the Cabinet of Ministers of the Republic of Uzbekistan dated September 22, 2021 No. 595 “On Measures for Further Improving Taxpayer Registration and Simplifying the Procedure for Value Added Tax Refund”.

For officials and enterprises, liability arises:

For violation by manufacturers and importers of the established procedure for mandatory digital labeling of certain types of goods;
For failure to equip with automated accounting devices, if such an obligation is established by legislation.

For these violations, the following fines are предусмотрены:

For officials — in the amount of 100 base calculation values (Part 4, Article 166 of the Code of Administrative Responsibility)
For enterprises — in the amount of the net revenue received in the last reporting quarter in which the sale took place (Article 227(1) of the Tax Code)

Deadlines for the prohibition of the sale of goods without digital labeling:

Goods	Prohibition date	Basis
Tobacco and alcoholic products	January 1, 2022	Clause 5 of Decree No. 737 dated November 20, 2020
Beer and beer products	April 1, 2022	Clause 5 of Decree No. 737 dated November 20, 2020
Alcoholic products in aluminum containers	December 1, 2022	Clause 5 of Decree No. 737 dated November 20, 2020
Alternative tobacco	October 1, 2023	Clause 3 of Decree No. 833 dated December 31, 2020
Vacuum cleaners, washing machines, refrigerators, freezers, televisions and monitors	October 15, 2022	Clause 2 of Decree No. 148 dated April 2, 2022
Household gas stoves, hoods, ovens and stoves, microwave ovens, irons, water heaters	February 1, 2023	Clause 2 of Decree No. 148 dated April 2, 2022
Water heating boilers, air conditioners, household appliances with built-in electric motors (juicers, blenders, mixers, coffee grinders, meat grinders), lamps of all typesWater heating boilers, air conditioners, household appliances with built-in electric motors (juicers, blenders, mixers, coffee grinders, meat grinders), lamps of all types	May 1, 2023	Clause 2 of Decree No. 148 dated April 2, 2022
Medicinal products released in secondary (outer) packaging (except orphan medicines)	August 1, 2025	Clause 2 of Decree No. 149 dated April 2, 2022
Medicinal products released in primary (inner) packaging (in the absence of secondary (outer) packaging) and medicinal bulk products (except orphan medicines)	October 1, 2025	Clause 2 of Decree No. 149 dated April 2, 2022
Orphan medicinal products approved by the Ministry of Health of the Republic of Uzbekistan, as well as included in the State Register of Medicines, Medical Devices and Medical Equipment within the framework of the procedure for recognition of registration results carried out outside the Republic of Uzbekistan	March 1, 2026	Clause 2 of Decree No. 149 dated April 2, 2022
Medical devices included in the list approved in the established manner. At the same time, the list of medical devices is approved by the State Tax Committee and the Ministry of Health based on the results of the pilot project on digital labeling of these products	February 1, 2028	Clause 2 of Decree No. 149 dated April 2, 2022