Russia Regulatory Updates

This is a compilation of the recent regulatory updates from Russia. Every week, we post an update of what's new, which you can view here.

2019

• November 3: Russia’s State Duma published an amendment proposal to request a six-month transition period for the implementation of product marking and reporting regulations. No final decision has been made.
• October 20: A working group in Russia’s State Duma is considering a six-month transition period for the rollout of marking and compliance reporting requirements. The proposed transition period would begin on January 1 and end on June 30, but no final decision has been made.
• September 29: Russian authorities published an amendment to decree number 1556 that slightly modifies processes related to code acquisition, applications, usage, and payments. Going forward, either pre-payment or post-payment for crypto codes will be accepted. The government also updated tertiary-level packaging requirements. Additionally, Technical Guideline version 1.32 published with a new code_emission event added. Finally, a new draft amendment for contracting and provisioning crypto codes for foreign producers was published. 
• September 8: A new Russian government decree that modifies serialization requirements for pharmaceutical supply chain companies has been published. Among other things, Russia Government Decree No. 1118 shortens required crypto codes and sets 180-day deadlines for payments and reporting.
• July 18: CRPT published updated technical guidelines (v1.31), along with new reports that are primarily related to domestic production.
• July 7: CRPT has made v1.30 of the technical guidelines available via its website.
• June 23: The Eurasian Committee published draft requirements highlighting the use of crypto coding for the EAEC countries in alignment with Russia's requirements.
• June 16: Six industry associations published an open letter to the government asking to initiate discussions around industry readiness and a potential shift in the final deadline.

2018

• December 30: Government decree # 1577, which covers the 2019 requirements and deadlines for the 12 Nosologies medicines, was passed and published.
• December 30: Government order # 2963-p was signed, making the multi-industry system of marking and traceability of goods official. This order mandates the usage of crypto technologies in product identification. Medicines for medicinal usage were included, despite the industry's pushback and request for crypto for drugs to be removed.
• December 16: The Association of International Pharmaceutical Manufacturers (AIPM) is preparing a letter that will ask the government to shorten the size of the crypto tail to 44 characters to help ease issues occurring at packaging with the current length of 88 characters. Considering the domestic pharma support by government for longer coding, it's unclear what the response will be to this request.
• December 16: The AIPM has also stopped lobbying for an adjustment to the full implementation deadline of January 1, 2020, as that deadline is now final.
• December 9: New draft technical guidelines have introduced some significant changes into the track and trace guidelines. The 12 Nosologies deadline may end up being in October of 2019, but there has not yet been an official confirmation.
• October 21: CRPT posted a draft implementation guideline for testing the generation, application, and verification of the crypto-protected product identifier.
• October 14: CRPT is holding an educational webinar this coming week on serialization and cryptography for a multi-national pharma audience.
• September 30: CRPT published an extensive Q&A regarding their operational takeover of the central IS Marking system from the Federal Tax Service.
• September 2: A new government decree marked as N. 1018 was published that formalizes the role of CRPT in taking over as operator of the central IS Marking system from the Federal Tax Service effective 11/1. The extension of the experimental pilot to 1/1/2020 was also formalized.
• August 3: The bill to expand the 7 Nosologies list (No. 511039-7) passed in the State Duma and has now been signed and published. The list of conditions has expanded to 12 and now includes hemolytic-uremic syndrome; juvenile arthritis with systemic onset; and mucopolysaccharidosis I, II, and VI types.
• July 22: Government has stated that the 7 Nosologies deadline will be extended to Apr. 1, 2019 and that cryptographic requirements for serialization will formally be required in the upcoming Roszdravnadzor regulations that are due in August.
• July 6: Intentions were confirmed this week around the cryptographic requirements for forthcoming Russia serialization requirements and models for how companies would use cryptographic services.
• June 29: An announcement was made that the track and trace government system is being transferred from the Federal Tax Service to CRPT (a private company), with operational turnover starting Oct 1. CRPT is one of the biggest supporters of the 791/792 cryptographic mandate, adding fuel to the expectation that crypto will be coming to Russia serialization. The expectation is that Roszdravnadzor will be publishing the final regulations in August.
• February 11: Roszdravnadzor published the updated technical interface documentation and regulations for interacting with the technical services (support) of the central FTS system.
• February 4: In an update to the FTS reporting system user guide, new GTIN allocation rules were posted, which apply GTINs to sites rather than a common GTIN across all products.