The Russian Government has introduced a two-year prohibition on the public procurement of foreign data storage systems.1

The prohibition applies to supplies, including leases, for governmental and municipal needs of almost all types of memory storage devices from foreign states, classified under code 26.20.2 of the all-Russia classifier of products based on types of economic activity OK 034-2014 ("OKPD2").2

The prohibition does not apply to data storage systems included in the unified state register of Russian radio-electronic devices ("Register").3

For inclusion into the Register4, the manufacturer of the devices should: (i) be a Russian legal entity; (ii) not be controlled by any foreign persons; and (iii) have manufacturing technology rights (patents, know-how, etc.), engineering and design documentation, and software allowing the manufacture of products for at least five years. The share of foreign components (if any) in the said devices should also be gradually decreased to no more than 15% by 2025, at the latest.

1 Russian Governmental Decree No. 1746 dated 21 December 2019 "On establishing a prohibition on the admission of certain types of goods originating from foreign countries, and amending certain acts of the government of the RF", came into force on 26 December 2019.

2 OKPD2 code 26.20.2 includes the following products: data storage device, internal storage device, external storage device, semiconductor storage device that retains information when power is turned off and semiconductor memory device that preserves information when power is turned off.

3 The Register is introduced by Russian Governmental Decree No. 878 dated 10 July 2019 "On measures of stimulation of manufacturing of radio-electronic products in the territory of the RF during the procurement of goods, works and services for state and municipal needs, on amending of Russian Governmental Decree No. 925 and repealing of certain acts of the Russian Government."

4 The statutory localization criteria are set by Russian Governmental Decree No. 719 dated 17 July 2015 "On confirmation of industrial manufacturing of products in the territory of RF."

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