National treatment for the purchase of medical products in Russia (GD No. 1875)

The national regime is designed to support Russian enterprises in government and corporate procurement. Resolution No. 1875 establishes a ban and restrictions on the purchase of a number of foreign medical products, as well as preferences for Russian analogues. It applies to purchases under 44‑FL (public procurement) and 223‑FL (procurement of certain categories of customers). The priority of Russian goods means that if there are domestic offers, foreign applications may be rejected. By introducing these measures, the law seeks to stimulate localization and reduce dependence on imports.
PP No. 1875 introduces three main mechanisms of the "national regime":
- Prohibition of purchases (Appendix No. 1) – goods listed in list No. 1 are not allowed at all when purchasing from foreign countries. 
- Restriction of purchases (Appendix No. 2) – according to list No. 2, purchases of foreign goods are limited if there are domestic offers. If the conditions specified in the resolution are met, foreign applications are rejected, and only Russian and EAEU goods are allowed.
 The advantage of the Russian Federation is that in all purchases, goods of Russian origin receive priority (quality/price assessment) if there are both domestic and imported items in the applications. The preference applies only to goods delivered to the customer during the purchase (not to purely works/services).
The appendices of PP No. 1875 list specific categories of medical devices that are prohibited or restricted. In addition, Appendix No. 4 sets the maximum allowable proportion of foreign materials in a number of products (for example, for blood transfusion equipment, no more than 10-40%). This is important when localizing production, since in order to confirm the domestic origin, it is necessary to comply with these limits and provide a certificate of the ST-1 form and a document on the actual proportion of imported components. The resolution also establishes the minimum share of purchases of Russian goods in public procurement under 223‑FZ (Appendix No. 3).
Criteria and mechanisms of application
Resolution No. 1875 clearly regulates how to apply prohibitions and restrictions. The customer evaluates the purchased product according to the OKPD2 codes and checks the lists No. 1 and No. 2. At the same time, an exact name match is not required: protective measures apply to all goods from the corresponding OKPD2 grouping. For example, if a product is purchased with a code included in the "Rubber garments" group (item 69 of Appendix No. 2), then all goods in this subgroup are subject to restrictions on the admission of foreign products.
Prohibition (Appendix 1): if the purchase concerns a product from List No. 1, any application with a foreign product is automatically rejected. The ban applies to any type of purchase.
 Restriction (Appendix 2): if the product is included in list No. 2, the customer verifies the applications: if there are at least two applications for goods of Russian or EAEU origin (similar in characteristics), applications with foreign goods are rejected. If there are not enough domestic offers, the purchase is carried out without restrictions under the national regime. The restriction applies only in competitive procedures and in requests for quotations/tenders with the submission of bids.
Advantage: if the goods from the lists and other goods are present in the purchase at the same time, then the advantage of "Russian" applies to the entire object of purchase. The preference applies to competitive and non‑competitive purchases with a single supplier (Part 12 of art. 93 44-FL).
When describing the product, it is important for the customer to comply with the requirements of Part 1.1 of art.33 44‑FL: the characteristics of the purchased medical device must correspond to at least one Russian equivalent. If there are no analogues, the customer can justify this in the TOR. After selecting the winner, confirmation of the origin of the goods by documents becomes a prerequisite for the contract. 
Documents confirming the origin of the goods
To apply the national regime, the supplier must confirm that the product was manufactured in the Russian Federation or the EAEU. PP No. 1875 specifies specific forms of confirmation:
For goods from lists No. 1-3 (items 1-433): an entry in the register of Russian industrial products (RRPP, Ministry of Industry and Trade) and, if necessary, a certificate of a special investment contract (SPIC). If the product is manufactured in the EAEU (except the Russian Federation), an entry in the Eurasian Register of Industrial Goods is required.
For goods from the EAEU: either an entry in the Eurasian register or a certificate of origin ST-1. The Ministry of Health and experts point out that other documents may be used for a number of medical devices (this transitional regime was in effect until August 2025). For example, for products from items 400-432 of Appendix No. 2 (medical clothing gloves, etc.) allowed the presentation of the ST-1 certificate, the act of the Chamber of Commerce and Industry and the document on the conformity of production with GOST ISO 13485. For items 362-399 (toiletries, apparatuses, etc.) and medicines of the 433rd, an entry in the RRPP registry was sufficient/The EAEU or the certificate of the authorized body of the EAEU.