To enforce anti-counterfeiting rights through Uzbekistan's customs border controls, a pharmaceutical rights holder must first satisfy two preliminary conditions: the relevant trademark must be registered with the Intellectual Property Agency of Uzbekistan (IPPA), and the mark must be listed on the Customs Register maintained by the Customs Committee of Uzbekistan. Without both registrations in place, customs authorities have no basis to act on the rights holder's behalf — border seizure measures are, as a general rule, unavailable to unregistered marks.
Trademark protection in Uzbekistan is territorial and registration-based. A foreign pharmaceutical company holding registrations in its home jurisdiction or at the EAEU level obtains no automatic protection under Uzbek law: Uzbekistan is not a member of the Eurasian Economic Union and has its own independent trademark register administered by IPPA. Applications to IPPA typically take between 12 and 18 months to reach registration, depending on examination and any opposition proceedings. Pharmaceutical brands subject to parallel import risk or known counterfeiting patterns in Central Asian supply chains should prioritise early filing.
Once IPPA registration is confirmed, the rights holder may apply to the Customs Committee to list the trademark on the Customs Register. The application requires proof of trademark title, a description of genuine product characteristics (including packaging specifications), and contact details for an authorised representative in Uzbekistan. The Customs Register listing enables customs officers to detain suspected infringing goods on an ex officio basis or in response to a rights-holder notification, typically for up to ten working days pending the rights holder's verification and decision on whether to pursue a formal complaint.
Note: A rights holder that has not completed both the IPPA registration and Customs Register listing before infringing goods enter Uzbekistan's territory will be limited to post-clearance judicial remedies through the economic courts. Recovering goods that have already cleared customs is substantially more resource-intensive and uncertain than intercepting them at the border.
Uzbekistan's enforcement framework operates on two principal tracks, and pharmaceutical rights holders should understand which applies to their situation before filing.
The administrative track is the standard route for customs enforcement. The Customs Committee detains goods suspected of being counterfeit, notifies the rights holder, and provides a window for the rights holder to submit an expert determination confirming the infringing nature of the goods. For pharmaceuticals, a parallel notification to the relevant health authority — the Agency for the Development of the Pharmaceutical Industry and the Sanitary and Epidemiological Welfare Service — is advisable where the goods in question may pose a public health risk. This dual-authority approach strengthens the procedural record and may accelerate the administrative decision.
The criminal track applies where there is evidence of organised counterfeiting activity or where the scale of infringement meets the threshold for criminal liability under Uzbek law. Referral to the Prosecutor's Office or the Ministry of Internal Affairs is typically initiated by the administrative authority, though a rights holder's legal representative may request a criminal investigation in parallel with the administrative complaint. In practice, criminal proceedings in IP matters in Uzbekistan remain less common than administrative ones, and the evidentiary standard is considerably higher.
A consideration specific to pharmaceuticals is the distinction between counterfeit medicines — those bearing a registered mark without authorisation — and falsified medicines, which may not bear any registered mark but are misrepresented as to their composition or origin. Uzbek health legislation addresses falsified medicines separately from trademark infringement, and rights holders dealing with falsified product should structure their complaint to engage both the IP and the health regulatory frameworks simultaneously.
The cross-border dimension is material for pharmaceutical supply chains transiting through Russia or Kazakhstan. Goods entering Uzbekistan through CIS transit routes are subject to Uzbek customs control at the point of entry into Uzbek territory. Because Uzbekistan is not an EAEU member, the harmonised EAEU customs enforcement mechanisms do not apply: each border crossing requires a separate enforcement action under Uzbek national procedure.
The following sequence reflects the recommended approach for a foreign rights holder seeking to establish and use enforcement capability in Uzbekistan.
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Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's IP and cross-border practice advises foreign companies — including those operating in CIS jurisdictions — on brand protection, enforcement strategy, and market-entry IP structuring. The firm collaborates with trusted local counsel in Uzbekistan and other CIS jurisdictions for matters requiring in-country registration or court representation.
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This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.
— Nodira Yusupova Contributing Regional Analyst — Uzbekistan, Vetrov & Partners vetrovpartners.com/contributions/