Minor breaches, massive fines: Uzbekistan’s marking rules weigh on businesses, tax adviser says

Fines for breaches of product-marking rules in Uzbekistan place a heavy burden on businesses, with recent changes exacerbating the impact, tax adviser Nodirbek Khojabekov told Kun.uz. Enforcement has led to multi-billion-soum penalties for minor infractions, he added.

“In one case, a product worth UZS 96,000 led to a UZS 140 billion fine. We proved in court it was not a marking violation but a breach of trade rules, and we won,” he said.

Under Article 221(1) of the Tax Code, such breaches carry a fine of 2% of quarterly turnover, rising to 20% for repeat offenses within a year. The framework is set out in Cabinet of Ministers Resolution No. 833, which targets manufacturers and importers supplying unmarked goods and aims to prevent large volumes from entering the market. Khojabekov said the approach was initially justified.

However, enforcement has since broadened.

“Even in routine retail – for example, when a low-cost painkiller or drink fails to scan – fines equal to 2% of quarterly turnover have been imposed,” Khojabekov noted.

He pointed to large pharmacy chains with hundreds of outlets, where a single low-value sale at one branch can trigger penalties based on the chain’s total turnover. The resolution, he said, limits such provisions to manufacturers and importers, while retail and wholesale cases should fall under trading violations. In practice, however, turnover-based fines have also been applied to individual retail transactions.

“For example, if a pack of 10 Citramon pills is sold and the marking fails to scan, the fine is calculated on the company’s total turnover,” he said.

In one case, a company whose core business was manufacturing, with turnover of UZS 120 billion, alongside hospitality and catering, was fined on its full turnover after a UZS 96,000 item was sold without proper marking at a bar.

“We showed in court that this practice went against Resolution No. 833, as the rule should apply only to manufacturers and importers,” Khojabekov said.

Amendments later expanded the scope. Since January 23, 2026, selling goods individually without proper marking is also classified as a violation.

“As a result, even a single failed scan in a pharmacy or supermarket can trigger a fine of 2% of quarterly turnover. This is pushing companies towards bankruptcy,” Khojabekov stressed.