Law No. 37 of 2010 Cannot Be Verified and Should Not Be Cited

1. Key takeaways

A Law No. 37 of 2010 on the Registration and Importation of Pharmaceuticals and Medical Devices was not found in ECOLEX, FAOLEX, the Iraqi Ministry of Justice legal database, or the Iraqi Official Gazette; the name appears only in content farms and their mutual republications, and some secondary sources call it No. 37 of 2013, contradicting themselves on the year. GRZAN’s finding: it is highly suspected to be fabricated or seriously misquoted, but no definitive assertion is made before the MOH website and the official legal database become reachable; in practice it is barred from appearing as a legal basis in any tender, contract, authorisation letter, or compliance document.

• Law No. 37 of 2010 (or 2013, depending on the source) has zero results across ECOLEX, FAOLEX, the justice ministry database, and the gazette.
• The verified parent statute is Public Health Law No. 89 of 1981 with four amendments, none numbered 37.
• The claim must not appear as a legal basis in any client-facing document.
• Positive replacement citations exist: Articles 41/42, 105, and 3 items 11 and 12.

2. Legal basis

The alleged law, the verified parent statute, and the verified amendment list are set out side by side below.

Source grade. The Public Health Law and its amendments: primary, verified. The alleged Law No. 37 of 2010: not found, no definitive assertion; the finding rests on searches of ECOLEX, FAOLEX, the justice ministry database, and the Official Gazette, all zero. Because the MOH website and the justice ministry were unreachable, the wording is not that the law does not exist.

Evidence boundary. The Iraqi official domains reachable during this verification were kimadia.gov.iq, mop.gov.iq, cosqc.gov.iq, and cabinet.iq; moh.gov.iq and its legacy mirror were blocked sitewide by Cloudflare, moj.gov.iq failed to connect, and parliament.iq failed the reachability check. The negative conclusions should be rechecked once those sites become reachable again.

Verifiable search facts:

• In the ECOLEX legislation list for Iraq, Public Health Law No. 89 of 1981 and its 4 amendments are all locatable; records for No. 37 of 2010 total zero.
• In the FAOLEX Iraq collection, the Public Health Law carries number LEX-FAOC149622; entries for No. 37 of 2010 total zero.
• The Ministry of Justice database and the Official Gazette could not be searched directly this time; in the amendment histories recited by the copies of the Public Health Law they host, No. 37 of 2010 likewise never appears.

3. Expert insights

Insight 1: the three-step refutation method: gazette, legal databases, official architecture documents. Step one, the gazette: every Iraqi law must be published in the Iraqi Gazette; what is not published is not a law. Step two, the databases: ECOLEX and FAOLEX index Iraqi law in force; a zero result makes the claim highly suspect. Step three, official architecture documents: if a device registration and importation law really existed, the ministry’s own country profile and the WHO review could not omit it entirely. Three negative results support the judgment highly suspected unverifiable, with no definitive assertion while source sites are unreachable.

Insight 2: why such phantom laws survive for years. On the demand side, device professionals want a law to rely on; a statute spelling out registration and import rules sells better than none. On the supply side, content farms mass-produce country regulation entries by keyword and scrape one another, closing the loop. The harder legal texts are to obtain and the less stable official sites are, the more entries that merely look like regulation will breed.

Insight 3: a self-contradictory year is strong evidence. The same instrument is tagged 2010 in some republications and 2013 in others; number, year, and gazette issue are bound together and do not drift. Drift shows the source never held the original text.

Insight 4: who pays for a mis-citation. A company citing a non-existent law in a tender risks being judged as misunderstanding local regulation, or filing false material at worst. GRZAN front-loads this verification: any local regulation a client brings in first goes through the three-step refutation method.

Insight 5: reverse verification: using the parent law’s own entry-into-force clause to anchor the parent law as No. 89 of 1981. GRZAN’s anchor is the closing provision of the Public Health Law itself: Article 106 provides that the law entered into force 60 days after publication in the official gazette, a self-contained effectiveness mechanism independent of any secondary catalogue. Set against the amendment list it cross-verifies: No. 53 (1986) replaced Articles 41/42, No. 54 (2001) replaced Articles 26/96/99, No. 20 (2021) amended 2 articles, each stacking onto the same parent law. For the alleged No. 37 of 2010/2013 to be real it would have to appear on this amendment chain; its absence is the counter-evidence.

Insight 6: three external corroborations fixing the index conclusion that record number 117089 points to Law No. 89 of 1981. First, same-day news: official reporting on the 1981 promulgation day should match the text. Second, record number and law title map one to one: entry 117089 in the Iraqi official legal database corresponds to the Public Health Law No. 89 of 1981. Third, institutional consistency: the executing body is stated from the outset as the Ministry of Health, corroborating Article 3 items 11 and 12. All three must hold before the index conclusion enters external documents. In any market where legal texts are hard to obtain, what is truly reliable is not that a law was found, but that title, number, effectiveness clause, and executing body close into a loop.

4. Practical recommendations

• Any Iraqi regulation intended for a tender or authorisation document must be supported by three items: the Arabic full title, the number and year, and the gazette issue; lacking any one, it may not be cited as a statutory provision.
• Where materials from agents contain No. 37 of 2010 or No. 37 of 2013, return them and demand the gazette source; failing that, delete them from the dossier.
• Keep a blacklist of refuted entries, tagged with the refutation date and search path, so the same mis-transmission cannot revive.
• Substitute real provisions: for import licensing cite Articles 41 and 42, for ministerial delegation Article 105, for the duty scope Article 3 items 11 and 12, stating each scope limit alongside.
• Run a regulation authenticity briefing for the client and deliver a checklist of the three-step refutation method. Practical estimate: a complete three-step verification usually takes 1–2 working days (no official provision found).

5. Verification checklist

• □ In ECOLEX retrieve the legislation list for jurisdiction Iraq and confirm no record for No. 37 of 2010.
• □ Search the FAOLEX Iraq collection for the same name and confirm a zero result.
• □ Search the justice ministry database (moj.gov.iq) and the Official Gazette catalogue for a matching issue entry (mark as pending verification where the source site is unreachable).
• □ Run down the Public Health Law amendment history and confirm no No. 37 amendment in either 2010 or 2013.
• □ Search the WHO review and the MOH country profile and confirm neither cites that law.
• □ Trace citations of the sources proposing that law and confirm whether they are mutual republications of the same secondary publication.
• □ Recheck whether the documents cited here have been superseded (verification date: 29 October 2026).

Regulatory information verified as of 29 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Iraqi market. Our team manages KMOC (Kurdistan) and federal MOH registration procedures, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com