Amendments to Legislation on Control and Supervision Providing for the Immediate Prohibition of the Sale of Products, Including those Subject to Mandatory Labelling

On 24 June 2026, Draft Law No. 1209354-8 “On Amending Certain Legislative Acts of the Russian Federation” (“Draft Law”) was passed at first reading.

The Draft Law aims to establish a mechanism for control and supervisory authorities to respond promptly to threats to the life and health of citizens arising from the circulation of products, including goods subject to mandatory labelling.

Subjects of New Provisions

According to the text of the Draft Law’s amendments, if an order to suspend sales does not specify a particular addressee, it is binding on everyone who trades in the relevant products. Thus, the changes will affect not only manufacturers. The mechanism will apply to the entire supply chain – importers, distributors, retail outlets and marketplaces. Consequently, even a company that does not manufacture the goods but is involved in the supply chain for a particular product is obliged to monitor such bans and promptly take appropriate measures to withdraw the goods from sale.

The Essence of the Changes

To implement the response mechanism described, amendments are being made simultaneously to several laws in a coordinated manner.

Appeals

The Draft law also provides for the possibility of appealing against orders by persons for whom they are binding, in accordance with the procedure laid down in Chapter 9 of Federal Law No. 248-FZ of 31 July 2020 No. 248-FZ “On State Control (Supervision) and Municipal Control in the Russian Federation” and Article 54 of Federal Law No. 52-FZ of 30 March 1999 “On the Sanitary and Epidemiological Well-being of the Population”.

Specific rules governing the adoption and revocation of decisions to issue an order must be approved by the Government of the Russian Federation. It is further stipulated that, once the grounds for suspending (prohibiting) sales have been removed, a decision to resume sales of the products must be taken within three (3) working days, and this must also be published on the regulatory authority’s official website.

Risks for Businesses

• For goods subject to mandatory labelling (e.g., Dietary Biologically Active Additive), there may be unannounced inspections to verify compliance with labelling requirements;

• The immediate suspension (ban) of the sale of any products posing a threat to the life and health of citizens, regardless of whether they are subject to mandatory labelling. For labelled goods, enforcement of the ban is technically facilitated through the GIS for monitoring the circulation of goods, which in practice may render the sale of such products impossible;

• The manufacturer’s obligation to communicate the sales ban to an unspecified group of people, and the publication of the ban on the department’s website – reputational risks.

What We Recommend Doing Before the Regulations Come into Force

• Conduct an internal audit of products to ensure compliance with mandatory safety requirements as a whole, including, but not limited to, requirements for the labelling of goods with means of identification;

• Prepare for unannounced inspections: brief staff and ensure that documentation confirming product safety and compliance with certification (declaration) requirements is available and accessible;

• Discuss internal response procedures and coordinate the actions of participants in the supply chain (importers, distributors, retail outlets, marketplaces) in the event of a suspension (ban) on sales – for both labelled and unlabelled products.

Current status of the Draft law

The Draft law is currently under consideration in the State Duma. If the Draft law be passed in three readings, the provisions described here will come into force on 1 March 2027.

Risk Indicators Proposed by the Ministry of Health

We would also like to draw your attention to the fact that in March 2026, the Ministry of Health presented a draft (ID: 165890) of a list of risk indicators, based on data from the GIS, on the basis of which regulatory authorities will be able to carry out unscheduled inspections. Such indicators include, for example:

• abnormally rapid issuance of certificates of conformity for goods;

• documents confirming the safety of goods issued by a laboratory whose test reports have been deemed invalid on more than five occasions within a calendar year;

• cases where goods are labelled as “manufactured in the Russian Federation”, even though the specified manufacturer has no actual production facilities;

• sales at a price below 30% of the average market price for the following goods: