The list of specific products, the type of software affected and the procedure for installation will be determined by the Government later. The new rule is expected to apply primarily to smartphones, computers and televisions with a Smart-TV function.
As drafted the new requirements may potentially apply to a wide range of goods: from watches and household electronic appliances to system units and vehicles2.
It is not clear if consumers will be able to remove pre-installed Russian software.
Additionally, the State Duma is currently reviewing the draft law on liability for violation of these sales rules. As of the date of this alert, the fine for legal entities is proposed from RUB 50,000 to RUB 200,000.
Actions to consider
Given the legal and technical uncertainties of the implementation of this law, we recommend that manufacturers and sellers of electronic products, as well as developers of Russian software, take an active part in the public discussion of the drafts on implementing these regulations.
1 Federal Law "On Introducing Amendments into Article 4 of the Law on Protection of Consumer Rights" №425-FZ dated 2 December 2019.
2 The list of technically complex products is approved by Resolution No. 924 of the Government of the Russian Federation dated 10 November 2011.