On 2 July 2026, the Russian Government published RF Government Resolution No. 821 “On the Procedure for the Verification by the Operator of an Intermediary Digital Platform of the Information Contained in a Product, Work or Service Card Placed on the Intermediary Digital Platform, as Provided for in Clause 1 of Part 1 and Part 2 of Article 7 of the Federal Law ‘On Certain Issues of Regulating the Platform Economy in the Russian Federation’” (hereinafter, the “Resolution No. 821”).
Regulatory Context
Resolution No. 821 was adopted to implement Federal Law No. 289-FZ of 31 July 2025 “On Certain Issues of Regulating the Platform Economy in the Russian Federation” (hereinafter, the “Platform Economy Law”), which enters into force on 1 October 2026.
Article 7 of the Platform Economy Law imposes on digital platform operators (the “operators”) the obligation to verify the information placed in a product card and prohibits the placement of cards containing information on the sale of goods withdrawn from circulation, as well as pesticides and agrochemicals, dietary supplements, medicinal products and medical devices that have not undergone the requisite state registration.
- «Digital platform operators» are companies and individual entrepreneurs that own an intermediary digital platform enabling interaction between different groups of users and facilitating the conclusion of civil-law contracts. Operators may include, for example, marketplaces and service aggregators.
In fulfilment of the operators’ obligation set out in Article 7 of the Platform Economy Law, Resolution No. 821 approves three new instruments:
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the Rules for Verifying Information in a Product Card;
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the List of Information Systems Used in the Verification of Product Cards;
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the Rules for the Operator’s Interaction with the Operators of Information Systems Used in the Verification of a Product Card.
Verification of Product Cards
1. General rules
Prior to placing product cards on marketplaces, or upon making changes to them, operators will be required to carry out a verification comprising two stages:
At the first stage, the operator verifies the HS code (Harmonized System code) or OKPD 2 code (Russian Product Classification Code) and assesses whether a special verification is required.
At the second stage, the operator carries out one or more special verifications. Such verifications cover the most significant categories of goods affecting the safety and health of citizens, such as:
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Medicinal products;
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Medical devices;
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Dietary supplements;
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Products subject to mandatory labelling in the State information system for monitoring the turnover of goods (“GIS”), and others.
The verification is carried out using data from 12 state information systems and registers, including:
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The State Register of Medicinal Products for Human Use (GRLS);
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The Monitoring System for the Movement of Medicinal Products for Human Use (MDLP);
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The Register of Trademarks, and others.
The operator carries out the verification within three (3) business days from the date on which the partner (seller / service provider) submits the information required for the special verification.
Once the accuracy of the information is confirmed, the card is admitted for placement.
2. Verification upon amendment of product cards
Where the partner (seller / service provider) makes changes of the kind specified in Resolution No. 821 to the information in a product card, the operator suspends the placement of that product card and may not admit it for further placement without carrying out a verification.
3. Verification of the currency of information
Thereafter, in order to keep the information current, the operator is required to carry out a periodic verification at least once every ten (10) business days.
4. Confirmation of the right to use a trademark
Resolution No. 821 introduces a mechanism for confirming the right to use a trademark. Using the Register of Trademarks and the documents provided by the partner (seller / service provider), the operator verifies the registration of the trademark and the right to use it. Following a successful verification, an image of the trademark will be displayed in the product card.
This mechanism provides an additional tool for protecting rights holders and bona fide sellers against the unlawful use of means of individualisation and the sale of counterfeit goods, and, for consumers, it may serve as confirmation of the lawful circulation of the goods. The provisions of Resolution No. 821 concerning the confirmation of trademark rights enter into force on 1 March 2027.
Entry into Force and Transitional Provisions
Resolution No. 821 enters into force on 1 October 2026, concurrently with the Platform Economy Law, save for the provision on the verification of trademarks.
A transitional period is provided for goods whose cards were placed before 1 October 2026. Such cards are subject to verification within 180 days from the date on which Resolution No. 821 enters into force.
Conclusion
By introducing verification of the accuracy of product information, Resolution No. 821 will require marketplace sellers to review, well in advance, the registration, permit and title documents for goods in the regulated categories. Market participants should pay particular attention to the transitional period applicable to product cards already placed, as well as to the procedure to be followed when subsequent changes are made to a card.
Resolution No. 821 logically continues the subject of our previously published review of amendments to the legislation on control and supervision (Draft Law No. 1209354-8), which are aimed at establishing a mechanism for the prompt reaction of control and supervisory authorities to threats of harm to the life and health of citizens in the circulation of products, including goods subject to mandatory labelling.
Draft Law No. 1209354-8 governs the consequences of detecting violations after the goods have already entered into circulation, whereas Resolution No. 821 establishes a system of additional verification of the most significant categories of goods affecting the safety and health of citizens at the stage of placing their cards on marketplaces.
Together, these acts form a comprehensive system for controlling the turnover of products.