In late November, Russia’s Ministry of Industry and Trade proposed a regulation introducing a scoring system to confirm the localisation of pharmaceutical production within the Eurasian Economic Union (EAEU). Scheduled to take effect in July 2025, this regulation is part of a broader policy to reduce industrial import dependence while stimulating local production.

The proposed regulations will impact all stages of pharmaceutical manufacturing – from active pharmaceutical ingredients to finished products – affecting eligibility for government procurement and state support for both international and domestic pharmaceutical companies. This, in perspective, will affect overall access to the Russian market.

However, the experience in implementing the scoring system in other sectors (i.e. automotive and chemicals) shows that its straightforward introduction makes it nearly impossible to meet the localisation criteria. Coupled with other restrictions for “non-EAEU” products (e.g. “second-one-out” in public procurement), this could result in a significant loss of market share and create dependence on the need to obtain “temporary” informal exemptions.

For more implications for the Localization Score Shake-Up in Russia, see our memo below.