Uzbekistan Asl Belgisi Digital Marking for Medical Devices: Requirements and Timeline

1. Key takeaways

Asl belgisi is the mandatory digital marking system of Uzbekistan, and medicines and medical devices are included in the mandatory marking group. Under Presidential Decree No. UP-296 (October 6, 2025), the digital marking system becomes fully effective from March 1, 2026 — goods whose validity has expired or whose marking is non-compliant are automatically blocked at the point of sale. The system operator is CRPT Turon LLC; coding must be completed before import, and system registration, code range applications, data submission and continuous compliance must be carried out by the local representative holding an electronic signature. The practical meaning of automatic blocking is worth spelling out: a product without a valid code is not merely exposed to fines or retrospective penalties, it simply cannot complete a sale, because the checkout and wholesale transfer processes read the code status in real time. Compliance is therefore binary — the code either validates or the transaction does not happen. For importers of medical devices, this converts marking from a labeling task into a systems integration task: the representative needs an account with the operator, a funded code range, a product card in the national catalog for every model, and a working declaration flow for each import batch. None of these can be improvised after the goods arrive, because coding is a pre-import condition. Devices that also carry a UDI under the registration dossier must reconcile the two identifiers so that the code applied to the physical product matches what the registration documents record. Because the code ranges are drawn from a prepaid account, budget discipline also matters: a depleted balance at the moment of a planned shipment stops the coding step entirely, and with it the import itself. Keeping the account funded and the code range register current should be treated as part of ordinary inventory management rather than as a special regulatory project.

2. Legal basis

3. Expert insights

Insight 1: coding moves the obligation from the sales side to the import side. For devices subject to national UDI coding, coding must be completed before import, and the representative must conclude an agreement with the national digital coding operator and register every imported batch. Shipment plans must therefore reserve time for coding — shipping first and applying codes later is not workable in practice. Companies that discover this rule after their first shipment typically face the choice between returning the goods or arranging coding at the border, both of which cost far more than planning the step in advance.

Insight 2: the code moves through five stages, each with its own action. The system splits the code lifecycle into: system registration and agreement; creation of the product card in the national catalog; application for code ranges (prepaid account); declaration of introduction into circulation at production or import; and wholesale transfer via electronic invoice and retail exit via receipt. A gap at any of the five stages breaks the status chain of the code, and the break only becomes visible when a transaction fails, which is the most expensive moment to learn about it.

Insight 3: the code and the tax system converge at the retail end. From July 1, 2026, where code verification fails, an electronic invoice or receipt cannot be issued. This ties traceability compliance directly to tax compliance — a code problem means no invoice, and without an invoice the sale cannot be completed. Finance and regulatory teams therefore share the same operational risk and should monitor code status jointly rather than assigning it to one department.

Insight 4: the UDI is the interface between the registration dossier and the marking system. Item 2.1 of Resolution No. 738 and registration decree No. 3888 require a unique UDI code; the marking system uses the DataMatrix code to carry the GTIN and link to the product card in the national catalog. Both point to the same device identity, so the UDI should serve as the master data shared between registration and marking, avoiding two parallel coding schemes for the same product.

4. Practical recommendations

1. Have the representative complete system registration, agreement and product card creation before shipment, and include coding time in the shipment plan.
2. Maintain a code range register recording application, application of codes, introduction into circulation, transfer and exit for every batch.
3. Share the same master data between the registration UDI and the DataMatrix code of the marking system.
4. Complete end-to-end testing before the code verification rule takes effect (July 1, 2026), to avoid invoice issuance interruptions.
5. Confirm whether specific product items fall within the mandatory coding scope by IKPU and HS codes on aslbelgisi.uz and lex.uz.

5. Verification checklist

• □ Representative completed system registration and agreement with the national digital coding operator
• □ Product card created in the national catalog and linked to the GTIN
• □ Code range register covers application, application of codes, introduction into circulation, transfer and exit
• □ Coding completed before import
• □ Registration UDI and marking DataMatrix code share the same master data
• □ Specific product items confirmed by IKPU and HS codes on aslbelgisi.uz and lex.uz

GRZAN supports manufacturers, importers and authorized representatives with medical device registration, Asl belgisi digital marking onboarding and market access in Uzbekistan. For assistance with your product portfolio, contact info@grzanglobal.com.

Regulatory information verified as of October 29, 2026.