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From 1 July 2020 certain types of electronic goods could only be sold in Russia with pre-installed Russian software1.

The list of specific products, the type of software affected and the procedure for installation will be determined by the Government later. The new rule is expected to apply primarily to smartphones, computers and televisions with a Smart-TV function.

As drafted the new requirements may potentially apply to a wide range of goods: from watches and household electronic appliances to system units and vehicles2.

It is not clear if consumers will be able to remove pre-installed Russian software.

Additionally, the State Duma is currently reviewing the draft law on liability for violation of these sales rules. As of the date of this alert, the fine for legal entities is proposed from RUB 50,000 to RUB 200,000.

Actions to consider

Given the legal and technical uncertainties of the implementation of this law, we recommend that manufacturers and sellers of electronic products, as well as developers of Russian software, take an active part in the public discussion of the drafts on implementing these regulations.

Federal Law “On Introducing Amendments into Article 4 of the Law on Protection of Consumer Rights” №425-FZ dated 2 December 2019.

The list of technically complex products is approved by Resolution No. 924 of the Government of the Russian Federation dated 10 November 2011.



Edward Bekeschenko is a partner in Baker & McKenzie's Moscow office. He is ranked as a leading lawyer in dispute resolution by Chambers and Legal 500. Prior to joining the Firm in 2001, Mr. Bekeschenko headed the legal department of a major Russian metallurgical company and was vice president of a Belarusian law firm.


Nadia Goreslavskaya is a partner in the Moscow office of Baker McKenzie. She is experienced in antimonopoly regulation, corporate law and general commercial law matters and is recommended by Chambers Europe, being cited as "a rising star in [competition/antitrust]" and "establishing herself as an active and hands-on competition lawyer." PLC Which lawyer? Yearbook describes her as "building a strong presence in the market advising on the competition aspects of corporate transactions in the region."


Maxim Kalinin serves as managing partner of Baker & McKenzie’s St. Petersburg office and head of the Mergers & Acquisitions, Corporate, Real Estate & Construction and Employment practice groups. He was named a European legal expert in Russia by European Legal Experts 2008, and was recognized by Chambers Europe "for his expertise in M&A and real estate work". He is also cited by Legal 500, Who’s Who Legal 2009, The International Who’s Who of Real Estate Lawyers 2008 and the Private Equity Handbook 2007/2008 for his corporate and real estate work