Uzbekistan Power of Attorney and Legalization Chain for Medical Device Registration

1. Key takeaways

For a power of attorney issued by a foreign manufacturer to acquire full legal effect between the country of issuance and Uzbekistan, a document drawn up in Chinese must complete three steps in sequence: notarization in the country of issuance → notarized certification of the accuracy of the Uzbek translation (required by registration decree No. 3888, applicable from October 8, 2026) → apostille or consular legalization. The order of the three steps cannot be reversed, and each step involves a different competent authority. Placing the translation certification after the legalization step is the most common cause of rework in practice, because documents that have already been legalized must be processed again once the translation is certified separately. The practical consequence is calendar risk: the chain involves at least three authorities and two international mailings, none of which can run in parallel. Since the power of attorney underpins every action the authorized representative performs before the Center, from the initial submission through renewal, variations and the receipt of decisions, any defect in the chain does not merely delay one filing; it can freeze the entire regulatory workstream for the product line. Planning the chain as a scheduled critical path, with the power of attorney template confirmed before the technical dossier is finalized, is the reliable way to keep the sequence intact and avoid repeat legalization.

2. Legal basis

3. Expert insights

Insight 1: registration decree No. 3888 defines the language rule down to four specific languages. Powers of attorney drawn up in Uzbek, Karakalpak, Russian or English require no additional translation certification; all other languages, including Chinese, do. This rule creates a practical option: reissuing the power of attorney in an English version can remove the translation certification step entirely. Before taking that route, two points must be confirmed: the English version must be legally equivalent to the original document, and the signing entity and the wording of the granted authorities must be identical to those in the original. Where the manufacturer is a Chinese entity and the original corporate authorization is drafted in Chinese, an English reissue should be checked against the parent authorization to ensure no divergence in scope.

Insight 2: apostille and consular legalization are alternatives, not cumulative requirements. The wording of registration decree No. 3888 is notarization, apostille or consular legalization. The document flow route between the two countries should be determined according to the international conventions and bilateral arrangements in force at the time, and one of the two options is sufficient. Processing both not only adds cost but may cause the document to be rejected because of a conflict in its legal form. Verifying the current route with the receiving authority before starting the chain is cheaper than redoing the legalization after a rejection.

Insight 3: the content of the power of attorney should cover the full lifecycle to avoid repeat processing. The power of attorney should identify the correct legal entity, the signing authority, the scope of devices or products, the permitted actions and the period of validity. If it only authorizes the submission of a registration application, then the entire legalization chain must be processed again for renewal, variation and adverse event reporting. This is the most expensive kind of omission, because each reissuance restarts notarization, translation certification and legalization from the beginning.

Insight 4: the legalization chain is a non-compressible segment of the project schedule. The three steps involve at least three authorities and two international mailings, and none of them can run in parallel. GRZAN manages the chain as a critical path item and recommends confirming the power of attorney template before the technical dossier is finalized, so that document revisions do not trigger a new round of notarization and legalization. Building this buffer into the project plan protects the submission date.

4. Practical recommendations

1. Schedule the legalization chain in a fixed order: notarization in the country of issuance → translation certification → apostille or consular legalization.
2. Scope the power of attorney to cover submission, renewal, variations, receipt of decisions and post-market support, completing it once to avoid repeat processing.
3. Evaluate reissuing the power of attorney in an English version to remove the translation certification step, after confirming legal equivalence.
4. Confirm the power of attorney template before the technical dossier is finalized, so that document revisions do not trigger re-legalization.
5. Retain the processing receipts and completion dates for every step to support later review and expiry management.

5. Verification checklist

• □ The power of attorney has completed notarization in the country of issuance
• □ The power of attorney drawn up in Chinese has completed notarized certification of the accuracy of its Uzbek translation
• □ Apostille or consular legalization has been completed, choosing one option and not processing both
• □ The authority of the power of attorney covers submission, renewal, variations, receipt of decisions and post-market support
• □ The power of attorney template was confirmed before the technical dossier was finalized
• □ Processing receipts and completion dates for every step have been retained

GRZAN supports manufacturers, importers and authorized representatives with medical device registration, power of attorney legalization planning and market access in Uzbekistan. For assistance with your product portfolio, contact info@grzanglobal.com.

Regulatory information verified as of October 29, 2026.