Parallel import: which documents are needed for a product

Parallel import is often understood as a mode of “we import anything without papers”. In fact, it solves exactly one task: it removes the need to get the consent of the trademark rights holder. All the rest of the regulation stays in place.

What the mechanism gives and what it does not

The importer's steps

Documents: who issues them and for what

In parallel import, the applicant is the importer itself — a Russian legal entity or an individual entrepreneur. This means that the responsibility for the accuracy of the data also lies with the importer, not with the foreign manufacturer.

What most often goes wrong

• The brand code is there, but the model is not. The list is built by codes and brands; a specific item still has to be classified.
• A mixed batch. One delivery contains several categories, some of which need different regulations and schemes.
• Labelling in a foreign language. The label has to be supplemented to meet the requirements of the regulation.
• No evidence base. The foreign manufacturer does not provide test reports, and the tests have to be done again from the beginning.

Checklist before purchase

• The HS code (TN VED) is determined and checked against the parallel import list
• All applicable technical regulations are known
• An assessment scheme is chosen to suit the format of deliveries
• There is a plan for operating documents in Russian
• The testing time is taken into account in the delivery schedule
• It is checked whether the product falls under mandatory labelling

How not to make a mistake with the code, on which both the list and the regulations depend — in the basic article on the HS code (TN VED).

What remains mandatory

The brand list: how it works

Parallel import is allowed not “in general”, but selectively: there is a list of goods to which some provisions on the protection of exclusive rights do not apply. It is made by HS codes (TN VED) and brands, and this is an important detail — getting into the list is determined by the combination, not by the name of the brand alone.

• The brand is listed in full. All products of the brand can be imported within the stated codes.
• The brand is listed with a reservation on codes. Only what falls into the listed items is allowed: the brand's clothing may be allowed, and its perfumery not.
• The brand is not in the list. Import without the consent of the rights holder remains a violation of exclusive rights with all the consequences.

The list is reviewed: items are added and excluded. It must be checked on the date of the deal, not from memory of last year's delivery — the brand may have left it.

Acceptance on a marketplace

The platforms treat parallel import with caution, because this is where the complaints of rights holders arrive. In practice this shows up as additional requests.

Advice that saves weeks: collect this set right at the time of import, and not when the card is already blocked. Restoring documents afterwards, especially invoices from a foreign supplier, takes a long time.

Warranty and service

This is the side of the question that sellers think of last and buyers think of first. With parallel import, the brand's official service is not obliged to service the product: it has no contract with you, and the product did not pass through the official channel.

The seller's duties follow from this.

• The warranty obligations to the buyer are yours, not the manufacturer's
• You need to organize acceptance and repair or replacement at your own expense
• The buyer must not be misled by promising an “official manufacturer's warranty” if there is none
• In the product card it is worth stating honestly who provides the warranty service
• The instruction in Russian remains mandatory — its absence is a violation in itself

Separately, about software and subscriptions: equipment tied to regional services may partly not work. This is not a defect in the legal sense, but it is a reason for returns and claims if the buyer was not warned.

What to do if the delivery has already arrived and there are no documents

This situation is frequent: the product was bought and brought in, and the questions of conformity confirmation were dealt with later. The recovery order depends on what exactly is missing.

• No conformity document. It is issued for the batch: you will need samples, tests and an applicant registered in the Union. Until it is issued, the product cannot be sold.
• The document exists, but is issued to another person. You need confirmation of the right to sell from the holder, or your own document for your batch.
• No Russian-language labelling. It is applied before the product is put into circulation — that is, before the sale, not after the platform's request.
• No confirmation of import. It is restored from the customs declaration; without it there is nothing to confirm the legality of the batch.

What is almost impossible to fix afterwards is the absence of the product in the list. If the brand is not included in it, conformity documents do not save the situation: the claim will not be about safety, but about exclusive rights.