Who Needs to Comply?
Russian manufacturers
Russian manufacturers placing medical devices on the domestic market must:
- Register every device with Roszdravnadzor before commercial sale
- Obtain and maintain the necessary quality management system (QMS) certification where required by device class
- Report adverse events and safety information to Roszdravnadzor
- Maintain distribution records and cooperate with post-market surveillance
Foreign manufacturers
Foreign manufacturers wishing to sell medical devices in Russia must:
- Appoint a Russian Authorized Representative (RUS REP) before submitting a registration application — this is mandatory and cannot be bypassed
- Register every device via either the national or EAEU pathway
- Ensure all technical documentation is translated into Russian by a certified translator
- Comply with Apostille requirements for documents issued in foreign countries
See Authorized Representative (RUS REP) for full details.
Importers
Importers of medical devices into Russia must:
- Ensure the device holds a valid RZN Registration Certificate before importation for commercial sale
- Report every import of any medical device to Roszdravnadzor within 15 days of importation — this is a mandatory reporting obligation introduced in 2022 under Regulation No. 11020
- Maintain records of imported quantities and distribution
Distributors
Distributors operating in Russia must:
- Only distribute devices that hold a valid Registration Certificate
- Cooperate with Roszdravnadzor investigations and market surveillance activities
- Maintain records that allow traceability of devices distributed
Healthcare facilities
Healthcare facilities (hospitals, clinics) that use medical devices are also subject to specific reporting obligations — they must report adverse events and device malfunctions encountered during clinical use to Roszdravnadzor.
Official source
Federal Law No. 323-FZ, Article 38: base.garant.ru/12180860/