Tajikistan Medical Device Price Control and Reimbursement: Rules and Compliance Actions

1. Key takeaways

Tajikistan applies state price control to medicines and medical devices. Article 28 of Law No. 1893 provides that state supervision and inspection of price regulation and expense reimbursement for medicines and medical devices are carried out in accordance with the procedure determined by the Government. Article 8(13) and (14) further provide that the Ministry of Health establishes and approves the procedure for registering the final ex-factory prices of medicines of domestic and foreign manufacturers included in the list of essential medicines of the Republic of Tajikistan, and establishes the procedure for managing the state register of maximum ex-factory prices of medicines of domestic and foreign manufacturers on that list. GRZAN notes that the wording of Article 8(13) and (14) refers to medicines; the basis of price control over medical devices lies in Article 28 and Article 6(2)(6).

2. Legal basis

3. Expert insights

Insight 1: Article 28 places price regulation and expense reimbursement side by side, showing that Tajik price control covers the payment side. The provision speaks of state supervision and inspection of price regulation and expense reimbursement for medicines and medical devices. The implication is that the control covers not only sales prices but also the reimbursement stage. For device companies, products intended for public procurement or reimbursement systems require attention to both price registration and the reimbursement procedure.

Insight 2: Article 8(13) and (14) distinguish two mechanisms: registration of the final ex-factory price and the state register of maximum ex-factory prices. Paragraph 13 is a registration procedure (declaration by the company, approval by the Ministry of Health); paragraph 14 is a management procedure for a state register of maximum prices (setting a ceiling). Together they form a closed loop of declaration, determination and ceiling management. GRZAN notes that the wording of these two paragraphs refers to medicines; whether devices are subject to the same price registration procedure needs confirmation with the Ministry of Health, but the price control over medical devices under Article 28 is explicit.

Insight 3: Article 6(2)(6) lists price control as one of ten methods of state regulation. Among the ten methods enumerated in that provision, item 6 is state control over the prices of medicines, medical devices and parapharmaceuticals. This provision confirms that price control applies to medical devices and echoes Article 28. GRZAN recommends confirming whether a product falls within the scope of price control before entering the Tajik public market.

Insight 4: Article 12(4)(5) lists the obtaining of price information as one of the methods of state supervision. The provision provides that state supervision includes obtaining information on the determination and use of prices and mark-ups from state bodies and circulation subjects. The implication is that a company’s pricing and mark-up practices in Tajikistan are within the view of the supervisor. GRZAN recommends retaining pricing justifications and cost breakdown materials when building the price system, in preparation for possible inspections.

Insight 5: Article 22(4) assigns the categories, conditions and procedure of preferential supply to the Government. The provision states that the categories of persons entitled to preferential supply of medicines and medical devices, and the conditions, are determined by the Government. Read together with Article 4(4) (the principle of effective use of medicines and medical devices) and Article 22(3) (supply by medical institutions where there is no pharmacy in remote areas), Tajikistan’s supply security system is Government-led and covers special regions and special populations.

4. Practical recommendations

1. Confirm the scope of price control before entering the public market. Under Article 28 and Article 6(2)(6), confirm with the Ministry of Health and relevant Government bodies whether the product falls within price control and whether price registration is required.
2. Distinguish the two mechanisms of final ex-factory price registration and the maximum ex-factory price register. Under Article 8(13) and (14), prepare the declaration materials separately and confirm whether devices are covered.
3. Retain pricing justifications and cost breakdown materials. Under Article 12(4)(5), build a documentation ledger for prices and mark-ups covering pricing justifications, cost breakdowns and mark-up calculations, ready for inspection.
4. Track price registration and expense reimbursement in parallel. Under Article 28, where a product is intended for the reimbursement system, follow both the price registration procedure and the expense reimbursement procedure, each determined separately by the Government.
5. Track Government resolutions on preferential supply categories. Under Article 22(4), monitor updates of Government resolutions on the categories, conditions and procedure of preferential supply, and assess whether the product can enter the preferential supply catalogue.

5. Verification checklist

• □ Confirmed that Article 28 applies price control to medicines and medical devices
• □ Confirmed with the competent authority whether the product falls within the scope of price control (Article 6(2)(6))
• □ Distinguished Article 8(13) (final ex-factory price registration) from Article 8(14) (maximum ex-factory price register)
• □ Built a documentation ledger for prices and mark-ups covering pricing justifications and cost breakdowns (Article 12(4)(5))
• □ Tracked the price registration procedure and the expense reimbursement procedure in parallel (Article 28)
• □ Tracked updates of Government resolutions on preferential supply categories and conditions (Article 22(4))
• □ Assessed the coverage of the essential medicines list under Article 1(9) and its applicability to the product

Regulatory information verified as of October 29, 2026.

In the Central Asian market, the core capabilities of GRZAN focus on three points. First, distinguishing the different legal positions of each market within the Eurasian Economic Union: Kazakhstan and Kyrgyzstan are full member states where a choice exists between a national pathway and a Union pathway; Uzbekistan is an observer state with only a national pathway; Tajikistan and Turkmenistan are outside the Union framework and must follow purely national procedures. Second, local authorised representative services: GRZAN can act as the statutory representative of manufacturers in the above countries, undertaking registration submission, regulatory communication and post-market reporting obligations. Third, quality system and testing support: GRZAN assists in establishing a quality management system conforming to ISO 13485 and connects clients with locally accredited laboratory resources.

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