Tajikistan Law No. 1893: Legislative History and the 2025 Repromulgation by Law No. 2181

1. Key takeaways

The current fundamental law governing medicines, medical goods and pharmaceutical activity in Tajikistan is Law No. 1893 of July 19, 2022, titled On Medicines, Medical Goods and Pharmaceutical Activity. The law was adopted on May 25, 2022 by resolution No. 726 of the lower chamber, approved on July 15, 2022 by resolution No. 298 of the upper chamber, signed by President Rahmon in Dushanbe, and entered into force under Article 50 from the date of official publication. It repealed the Law on Medicines and Pharmaceutical Activity of August 6, 2001. GRZAN particularly notes that the version currently in force is the one repromulgated by Law No. 2181 of May 14, 2025, comprising 10 chapters and 50 articles.

2. Legal basis

3. Expert insights

Insight 1: The 2025 Law No. 2181 was not a patch but a full repromulgation of the law. Judging from the text of the current version of Law No. 1893, almost every article carries the annotation amended by Law No. 2181 of May 14, 2025, including the definitions in Article 1, the legislative purpose in Article 2, the scope of application in Article 3, the title of Chapter 4, and the repeal provision in Article 49. The judgment of GRZAN is that this amounts to repromulgating the entire law in a new version rather than amending individual provisions. The direct consequence is that any Tajik regulatory digest, internal training material or registration template formed before May 2025 must be re-checked against the current version.

Insight 2: The legislative history explains why old materials mislead people. The old 2001 law underwent repeated amendments in 2003, 2007, 2008, 2012, 2018 and 2021, and much of the Tajikistan registration material circulating in the market was formed between 2015 and 2021, citing the Order No. 736 system under the old law framework. The old law has been expressly repealed by Article 49, but Order No. 736 continues to function as a procedural document — creating a situation where the law has changed while procedural documents remain in transition, which is the root cause of inconsistent practical estimates.

Insight 3: Article 50, entry into force from the date of official publication, means there is no transition period. Unlike the transitional arrangements common in Kyrgyzstan, Kazakhstan and other states, Law No. 1893 entered into force upon publication. Enterprises must note in planning: the law contains no grandfathering clause for existing certificates, and the treatment of registration certificates obtained under the old law must be resolved through the re-registration and change procedures of Article 17(10) and Article 17(12), not through any bridging arrangement in the law itself.

Insight 4: The position of Chapter 3 deserves attention — quality control is placed before registration. Chapter 3, the state quality supervision system for medicines, medical goods, parapharmaceuticals and pharmaceutical activity, sits before the registration provisions in Article 17 and covers Articles 12 through 16. This shows the logic of the legislator: first establish the quality standards and supervision system, then address registration. For enterprises, quality documents (pharmacopoeias, technical specifications, quality control normative documents) are not accessories to the registration dossier but the foundation of the entire compliance system.

4. Practical recommendations

1. The first step of any project is to obtain the text of the current version. At the launch of every Tajikistan project, GRZAN retrieves the current version of Law No. 1893 through the ADLIA (MMIH) legal database of the Ministry of Justice or the National Center for Legislation under the President, rather than reusing historical versions.
2. Withdraw internal materials predating May 2025. Enterprises are advised to annotate version dates and withdrawal dates on Tajik regulatory digests within their quality system documentation, preventing project teams from citing outdated digests.
3. Distinguish between a law that has changed and procedural documents still in transition. The currently valid versions of procedural documents such as Order No. 736 must follow the latest announcements of the Ministry of Health; Article 17(12) has assigned the power to develop medical goods registration procedures to the Ministry of Health, and updates to procedural documents are routine.
4. Add Health Code No. 1413 to the mandatory reading list. Law No. 1893 cites the Health Code in numerous places (Article 9, item 3; Article 10; Article 14; Article 39(6), among others), and focusing only on Law No. 1893 will miss the higher-level basis for institutional powers and supervisory inspections.

5. Verification checklist

• □ Obtained the original text of the current version of Law No. 1893 repromulgated by Law No. 2181 of May 14, 2025
• □ Confirmed the legislative procedure: resolution No. 726 of 2022-05-25 by the lower chamber and resolution No. 298 of 2022-07-15 by the upper chamber
• □ Confirmed that Article 49 repeals the old law of August 6, 2001
• □ Confirmed Article 50, entry into force upon official publication, with no transition period
• □ Withdrawn internal Tajik regulatory digests formed before May 2025
• □ Obtained the latest announced versions of procedural documents such as Order No. 736
• □ Added Health Code No. 1413 (2017-05-30) to the project mandatory reading list

Regulatory information verified as of October 29, 2026.

In the Central Asian market, the core capabilities of GRZAN concentrate on three points: first, distinguishing the different legal status of each market within the Eurasian Economic Union — Kazakhstan and Kyrgyzstan are full member states offering a dual choice between the national track and the union track; Uzbekistan is an observer state with only the national track; Tajikistan and Turkmenistan are outside the union framework and must follow purely national procedures. Second, local authorized representative services, acting as the statutory representative of manufacturers in these countries and undertaking registration submission, regulatory communication and post-market reporting obligations. Third, quality system and testing support, assisting in establishing a quality management system that meets ISO 13485 requirements and connecting with locally accredited laboratory resources.

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