Parallel import China to Russia after 2022 legalisation: approved product lists, customs clearance, Rospatent risks and VAT treatment.
Russia introduced international exhaustion of intellectual property rights in April 2022, effectively legalising parallel import — the import of genuine branded goods without the trademark holder's consent in Russia. This removed a legal barrier that had previously protected authorised distributors' exclusive channels.
For Chinese companies, parallel import presents both opportunity and risk. Chinese manufacturers and traders can supply the Russian market through channels that previously required authorised distributor agreements. But Chinese brand owners with genuine Russian market presence face grey market competition from parallel importers — including parallel imports of Chinese goods from third countries.
Prior to April 2022, Russia applied national exhaustion — trademark rights were exhausted only upon first sale within Russia by or with the consent of the rights holder. Parallel import was trademark infringement. From April 2022, Russia shifted to international exhaustion for an approved list of goods — trademark rights are exhausted upon first sale anywhere in the world.
The approved list (Government Resolution No. 506 of April 2022, updated multiple times) covers approximately 50 product categories including: electronics, vehicles and spare parts, household appliances, medical equipment, cosmetics, clothing and footwear, agricultural equipment and chemicals. New categories are added periodically; check the current version before each import operation.
Parallel import in Russia applies to genuine goods — goods actually manufactured by or under licence from the rights holder. It does not authorise counterfeit goods, which remain subject to trademark enforcement and customs detention regardless of origin.
Practical consequence: a Chinese trading company can import genuine Apple iPhones purchased in Hong Kong or Singapore for sale in Russia, without Apple's consent for the Russian market import. A Chinese manufacturer of counterfeit Apple products cannot use parallel import as a defence — those goods are counterfeits, not genuine branded goods.
Parallel imported goods are cleared through Russian customs using the standard import procedure. Key differences from authorised import:
No authorised importer status required — any licensed importer can clear the goods
Customs value — declared at the actual purchase price; customs authorities apply risk profiles to detect undervaluation. Parallel imports of electronics from HK/Singapore are compared against known market prices
Trademark office check — Rospatent maintains a Customs Register of IP rights. Where the trademark owner has registered with the Customs Register, customs may notify the rights holder and hold goods for 10 business days. The rights holder can challenge the import but must do so on anti-counterfeiting grounds — parallel import itself is not a valid ground for seizure since 2022
Product certification — Russian/EAEU product certifications (GOST R, EAC marks) are still required for regulated product categories, regardless of parallel import status
Parallel imported goods pay the same customs duties and VAT as authorised imports. The parallel import legalisation did not change the tax treatment — goods subject to 5% customs duty and 22% VAT pay the same rates whether imported through an authorised channel or as a parallel import.
Input VAT on parallel imports is deductible by the Russian importer in the standard way, provided the goods are used in VAT-taxable activities and customs documentation is properly maintained.
Chinese companies that have built Russian distribution networks for their own brands face a specific risk: Russian distributors or other parties may begin parallel importing the Chinese goods from third-country markets (e.g., importing Chinese-brand products from the EU or UAE where they were sold at lower prices).
Mitigating this risk requires: contractual restrictions on the Chinese company's authorised distributors in other markets (prohibiting resale to Russia); consistent pricing policy that reduces arbitrage incentive; and active customs register registration to at least create notification triggers when parallel imports are attempted.
Chinese trading companies supplying the Russian market through parallel import channels typically use one of two structures:
Direct import through Russian LLC — Chinese trading company establishes Russian subsidiary; subsidiary imports and distributes. Cleanest structure; full VAT recovery; ability to build distribution relationships
Supply to Russian third-party importer — Chinese company sells EXW or FOB to Russian importer who handles customs clearance and distribution. Lower risk for the Chinese company; lower margin; less control over pricing and distribution
Parallel import legalisation has created genuine commercial opportunities for Chinese companies supplying the Russian market in categories where Western brands have reduced presence. The customs and tax framework is the same as for authorised imports — parallel import does not confer tax advantages, only distribution flexibility. Chinese brand owners need to manage the reverse risk: their own products being parallel imported into Russia from other markets at prices that undercut their authorised Russian distribution.
Related service: Company registration →Practical support for international business in Russia.