On 1 August 2026 Uzbekistan counted 57,163 commercial enterprises in wholesale trade, and only 421 of them were classed as large by the National Statistics Committee. Those large firms handled 26.4% of wholesale turnover in January to July 2026, so a foreign company looking for a distributor in Uzbekistan meets a wide field at the base of the market and a narrow one at the top. Official statistics describe the smaller wholesalers only in aggregate, leaving individual candidates largely invisible.

The choice carries more weight than the label suggests. The law on foreign economic activity grants the right to engage in foreign trade to legal entities registered in Uzbekistan and to resident individual entrepreneurs. Goods imported for resale therefore enter the market through a locally registered importer of record, a role that usually falls to the distributor. The import contract is registered in its name, and conformity documents and digital marking codes are often issued to it too. Its sales then leave an electronic trail in its own taxpayer account.

Selecting a distributor thus doubles as a decision about whose name will stand on the records that govern the market. This analysis asks what a foreign company can establish about a distributor before and after signing, and which records, alongside the contract, decide whether it keeps control, drawing on the questions that arise in market entry and partner mandates in Uzbekistan. Data run to 24 September 2026 and legislation to 25 September 2026, with adopted and planned measures kept apart.

Source: National Statistics Committee of Uzbekistan, annual wholesale trade by region and monthly wholesale trade by region, with other regions and shares calculated by Tretiakov Consulting.

Where Distributors in Uzbekistan Are Concentrated

The wholesale figures in this analysis are the National Statistics Committee's turnover data in soum at current prices. According to the statistics office's releases they include a statistical estimate of the unobserved economy, so they describe the whole wholesale market and not only the reported sales of registered wholesalers. Growth rates are real, in comparable prices, and dollar values are converted at the annual average official exchange rate in the World Bank series. Imports cover goods only, valued at cost, insurance and freight, and the dataset metadata do not state whether regional turnover is assigned by place of registration or by place of sale. Counts of enterprises are used only for broad changes, because the number of operating legal entities fell in the counts for 1 January 2024 and 2025 when the tax, statistics and justice registers were merged, which the office treats as a clean-up.

The series has been revised heavily, and every turnover figure comes from the latest vintage, updated on 10 and 24 September 2026, unless marked as first published. The first estimate for 2025, published in January 2026, was about 7% below the current figure. The latest levels imply a nominal rise of about half in 2023 against real growth of 15.6%, a gap not explained in the published sources, so real growth rates are the better guide to how fast the market has expanded.

Converted at annual average rates, the latest levels put wholesale turnover at about USD 17.3 bn in 2021 and USD 46.2 bn in 2025 (Tretiakov Consulting calculation), a rise that includes the unexplained 2023 step. Real growth was positive in every year of the period. The soum weakened against the dollar over those years, so growth measured in dollars is lower than growth measured in soum. In January to August 2026 turnover grew by a further 16.9% in real terms against the same months of 2025. The field has been open to new entrants for some time, since general licensing of wholesale trade was abolished from 1 January 2019 and licences now apply only in specific categories such as alcohol and medicines.

The chart shows how concentrated the market is across regions. Tashkent city accounts for more than half of wholesale turnover in every period, and together with the surrounding Tashkent region for about two thirds, while Fergana and Samarkand regions, the next largest, each account for less than a tenth. The capital's share rose further in January to August 2026, when its wholesale turnover grew by 20.7% in real terms, faster than the national total, although part-year shares are not strictly comparable with full years.

If turnover is booked where the reporting enterprise is registered, as enterprise-based reporting implies, the concentration shows where distributors keep their head offices, a separate matter from how goods reach regional bazaars and modern retail. On that reading most candidates with national reach are registered in the capital whatever the geography of their sales, although the metadata do not confirm it. Regional coverage therefore has to be established from a candidate's own sales records, which the regional statistics cannot replace.

Large enterprises handled about a quarter of wholesale turnover in each year from 2021 to 2025, on the first published figures, with small businesses accounting for the rest. The top layer is pulling ahead, and in January to July 2026 wholesale turnover of large enterprises rose by 31.7% in real terms against 10.0% for small business. The number of large wholesalers rose by more than a fifth between the start of 2025 and 1 August 2026. Large wholesalers had already grown faster than small ones in 2025, so the pattern covers two consecutive periods and points to consolidation at the top of the market.

Import data come closer to the question of distribution, because every product imported for resale needs an Uzbek importer. Goods imports rose from USD 23.7 bn in 2021 to USD 42.1 bn in 2025. Between those years the share of small businesses in imports of goods and services rose from 45.2% to 53.6%, so the importer behind a given product is increasingly likely to be a small firm, which the statistics describe only in aggregate.

Foreign investors have moved in step, with trade enterprises that have foreign shareholders rising from 3,782 on 1 January 2022 to 7,637 on 1 September 2026. At the later date they made up 35.5% of all such enterprises in the country, and across all sectors investors from China, Russia and Türkiye accounted for more than half of them. A candidate distributor may itself be foreign-owned, so establishing who stands behind it can lead beyond the Uzbek register. A pool of this size cannot be read from directories, which raises the question of which records show who already handles a given product.

Which Records Show Who Already Handles a Product

Online searches on how to find a distributor in Uzbekistan lead mostly to distributors' own websites and to directories. One national business directory listed 555 wholesalers in September 2026, with contact details but without taxpayer numbers or owners, and distributor websites describe coverage of tens of thousands of outlets that no public dataset confirms or refutes. Such listings show that a company exists and wants to be found, and they say nothing about which products it already imports.

A firmer trace lies in the documents that importing requires. Under the 2023 law on technical regulation, a declaration of conformity may be filed and a certificate obtained by the manufacturer, its authorised representative, a seller or an importer, and the document is issued in the applicant's name and entered in a register. Where an importer was the applicant, the register links a specific product to a specific Uzbek company. Whether these registers can be searched publicly by product and applicant remains unconfirmed.

In regulated categories the trace is narrower and specific to the product. Since 1 July 2025 imported medicines may be sold to wholesalers and pharmacies only by the importing company or by its official dealers, on the basis of an electronic invoice, under a presidential resolution of May 2025. The number of distributors registered in the digital marking system for medicines rose from 350 to 881 in the year to September 2024, according to figures presented at an industry round table and reported by the business press. Wholesale trade in alcohol is licensed under a 2023 law, and since 1 October 2024 licence conditions in that market have required digital marking, video surveillance of production and satellite tracking of transport, according to a news report on a presidential decree of June 2024. In these categories the set of lawful candidates is defined by a licence or, for imported medicines, by the importer's appointment of official dealers.

Several public and chamber institutions offer introductions to candidates. The United States Embassy in Tashkent runs a paid international partner search that returns up to five pre-screened companies within 30 business days, the German chamber network for Central Asia offers business partner searches, and the state Uzbekistan Investment Promotion Agency supports foreign investors. These services supply names and first-level screening, while the choice of entry route, including the choice between a distributor, a subsidiary and a joint venture, is a separate decision.

It is the records created by importing and selling a product that identify a credible candidate. Public procurement adds one more for suppliers to the state, since purchases run through a national electronic system, although how far its award records can be searched by outside users was not tested for this analysis. None of these records shows who owns the candidate, which is the next question.

Distributor Due Diligence in Uzbekistan and What Each Register Proves

Checking an Uzbek company's owners starts with the unified state register of business entities, kept under a 2017 Cabinet of Ministers resolution. A free online service gives access to a company's registration data by taxpayer identification number (TIN), which published descriptions say include its status, registration date, director and registered founders with their shares. The service requires a login through the national OneID system, for which a foreigner needs a passport and an Uzbek personal identification number, according to the government services portal. Since 2024 the register has carried additional information intended for creditors.

One recent change raises the register's weight, while two limits remain. Under the new law on limited liability companies, in force since 22 July 2026, the right to a share passes when the transfer is entered in the register, so for such companies the register entry now creates title to the share. A founder that is itself a company does not reveal the natural person behind it, however. The Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG) noted in its 2022 mutual evaluation that the registering authority had no obligation to verify the information supplied at registration. The register confirms what a candidate has declared about itself and cannot on its own establish ultimate ownership.

Information on beneficial owners is collected at registration but not published. Since 4 March 2021 each new legal entity has filed a questionnaire on its ultimate owner giving the owner's identity and citizenship, answering whether the owner holds senior public office and undertaking to report changes. Competent authorities have unconditional access to these data, according to the 2022 evaluation, but no public beneficial-ownership register could be located, and a 2022 draft lawon an open register has not been found adopted. The evaluation rated the transparency of legal persons as moderately effective, and the EAG follow-up report of May 2026 did not reassess that area. For a foreign principal the ultimate owner of a candidate is established through the candidate's own documents, with the register used to test them against the declared founders.

Tax data give the most current public signal about a candidate's conduct. A sustainability rating introduced on 1 February 2024 grades businesses from AAA to D, and since 5 December 2025 it has been calculated on 26 criteria averaged over 30 days. The Tax Committee states that the grades are published on the website of the Chamber of Commerce and Industry and shown in taxpayers' online accounts. In August 2024, under the earlier method, only about 1.6% of rated businesses held one of the three top grades (Tretiakov Consulting calculation from Tax Committee data), so a high grade sets a candidate apart from most of the field.

A candidate's value added tax (VAT) registration can be checked by TIN through the Tax Committee's online services, and a professional accounting publication describes a separate Tax Committee list of enterprises that abused the right to reduce VAT payable, likewise searchable by TIN. Neither record says anything about a candidate's financial capacity or solvency. Joint-stock companies publish financial statements on the national corporate information portal, but no public filing obligation was found for limited liability companies, so for a distributor organised as one the balance sheet comes only from the company itself.

Court and debt records are narrower than they appear. Final decisions of economic courts are published online only with the parties' consent or in anonymised form under a 2019 amendment to the Economic Procedure Code, so a search by a candidate's name cannot show its full litigation history. Pledges over movable property can be checked in the pledge register, and unpaid court-backed debts appear in the register of unsatisfied enforcement debts introduced in December 2024. A clean result in these registers shows that no problem has been recorded, and that falls short of evidence of solvency.

The only official record of contract performance located in the material reviewed comes from public procurement. Under article 48 of the public procurement law, a supplier that refuses to sign a contract it has won, fails to perform it, submits false documents or conceals an affiliation is barred from state contracts for two years. The Ministry of Economy and Finance keeps this register of unscrupulous performers under a regulation in force since 18 April 2025, although the number of entries was not found. The register covers conduct towards state customers only, so a clean entry says nothing about performance in private contracts.

On the last published breakdown by ownership, for 2021, state companies accounted for about 0.1% of wholesale turnover. A decree of June 2024 later removed the exclusive rights of state companies in the trade of several commodities, from scrap metal to natural gas and electricity, in stages to 1 July 2026. Where links to the state arise in distribution, they are more likely to run through state buyers and officials, the channel that recent laws address.

The law on conflicts of interest, in force since 6 December 2024, requires officials of state bodies and of companies in which the state holds 50% or more to report a conflict within one working day and to file an annual declaration. Internal anti-corruption units in such organisations were made independent under a presidential resolution of April 2025 and report to the chief executive or the supervisory board. A law of 22 June 2026 raised penalties for commercial bribery and wrote into the anti-corruption law the electronic register of persons convicted of corruption offences, created by a presidential decree of July 2021 that bars companies founded by such persons from public procurement. The Civil Codeallows a court to invalidate a transaction concluded through corruption, including through a conflict of interest. Partners that take equity, including state-owned ones, raise a different set of questions from those posed by a distributor.

Responsibility for sanctions screening divides between the Uzbek system and the foreign principal. Uzbek banks check clients against a domestic list of persons linked to terrorism or the proliferation of weapons of mass destruction, which takes in designations by the United Nations Security Council automatically. The 2023 follow-up report of the Financial Action Task Force (FATF) upgraded Uzbekistan's ratings on targeted financial sanctions to largely compliant. The bank rules reviewed for this analysis do not refer to the lists of the European Union (EU), the United Kingdom (UK) or the United States (US). Screening against those lists therefore falls to the principal, an inference drawn from the absence of any such requirement in the rules.

For suppliers based in the EU, two rules are relevant. Since 20 March 2024 Article 12g of Regulation 833/2014 has required exporters selling listed goods, including common high-priority items, to any third country outside a short list of partner states to prohibit re-export to Russia in the contract and to provide adequate remedies. Since the sanctions package of June 2024, EU parent companies must also use best efforts to ensure that the non-EU companies they own or control do not undermine the measures. A UK government guide published in 2025 lists warning signs that apply to any counterparty, among them recent incorporation or a recent change of owner, layered intermediaries, shared premises and unusual routes or payment patterns. These are compliance duties of the supplier and apply equally to distributors in any third country.

Uzbek public records confirm a distributor's legal standing but stop short of its ultimate owner

What each record establishes about a distributor, position on 25 September 2026

Source: Cabinet of Ministers resolutions 66 and 763, Presidential Resolution PP-39, Law on Public Procurement, Economic Procedure Code, Prosecutor General's order 3327 and EU Regulation 2023/2878.

Taken together, the public record shows who a candidate is in law and how it has behaved towards the tax authority and state customers, while its ultimate owner and capacity come from its own disclosures. That division sits at the centre of partner selection and verification in Uzbekistan, because the documents a candidate supplies are the only route to facts that no register holds. It leads on to the contract, since what the parties can fix in writing depends on the Civil Code and the 2023 competition law.

What a Distribution Agreement in Uzbekistan Can Secure

Uzbek law has no named distribution, dealer or agency contract. The Civil Code provides supply, commission, mandate and franchising as named types, and under the Code's rules on mixed contracts parties may combine elements of several in a mixed contract governed by the rules for each element. In practice a distributor that buys and resells is treated as a buyer under a framework supply agreement, while a sales intermediary acting for the principal's account falls under commission or mandate. Franchising is the one model with a formal step, since a franchise contract must be registered or it is invalid. A new edition of the Civil Code, published as a draft in 2020, had not been adopted by September 2026, so these named types remain the framework.

The Civil Code says nothing specific about exclusive distribution, so its limits come from competition law. The law on competition, in force since 4 October 2023, prohibits agreements between companies that do not compete with each other where they restrict or may restrict competition. Its examples are restrictions on a buyer's freedom to choose the territory or customers for resale, limits on resale prices and bans on selling other producers' goods. The same article exempts arrangements aimed at improving production, sales or competitiveness, and no market-share safe harbour for such vertical deals appears in the English translation reviewed. Dominance is presumed from a market share of 40%, and the fine for a prohibited agreement is 5% of each party's revenue over the period of the violation, counted for up to three years.

The 2023 law also left out an exemption contained in its predecessor. The 2012 competition law exempted from its ban on non-compete clauses agreements under which a buyer resells goods under the seller's trademark or other intellectual property rights, and the current article has no such item. Relations connected with exclusive intellectual property rights have been outside the law's scope since 2023, and an amendment of February 2026 narrowed that exclusion so that the ban on unfair competition applies to them, with effects on trademark licences that have not been tested. The statutory text appears to distinguish a principal's commitment not to appoint competing distributors in a territory from restrictions imposed on the distributor's own resale, and its examples concern the second kind. No published enforcement decision applying the article to an exclusive distribution arrangement was identified for 2023 to 2026, so the treatment of a given exclusivity clause turns on the restrictions it actually imposes and their effect on the market.

Sales targets and minimum volumes are not regulated by law. The supply rules allow a party to refuse performance unilaterally for a material breach, and the examples the Code gives are repeated late delivery, defects that cannot be cured, repeated late payment and repeated failure to collect goods. A missed sales target is not among them, and the general rule bars unilateral refusal unless the law or the contract allows it. A right to exit for underperformance therefore exists only if the agreement spells it out, which follows from how the provisions combine rather than from an explicit rule.

Termination works in a similar way, with the contract doing most of the work. A contract ends by agreement, or by a court for material breach once the other party has refused a proposal to end it or left it unanswered for 30 days, under the general rules on termination. In a commission the principal may withdraw at any time and must give 30 days' notice where the contract has no fixed term, and in a mandate either side may withdraw at any time, a right that cannot be waived. No statutory goodwill or clientele indemnity for distributors or agents was found in the provisions reviewed, so on exit the law provides only for expenses, remuneration for work done and general damages.

Uzbek law leaves most distribution terms to the contract and limits restrictions on resale

Treatment of the main terms of a distribution agreement, position on 25 September 2026

Source: Civil Code, Law on Competition, Law on International Commercial Arbitration, Cabinet of Ministers Resolution 283 and Law on Currency Regulation.

Parties may choose the governing law for the whole contract or for parts of it under the Civil Code's conflict-of-laws rules, and without a choice a sale is governed by the law of the seller. International commercial arbitration seated in Uzbekistan follows a 2021 law based on the United Nations model law, and the country has applied the New York Convention on foreign arbitral awards since 7 May 1996. A Supreme Court plenum resolution of November 2023confirmed that recognition of a foreign award may be refused only on the grounds listed in article V of the Convention. A presidential decree of 30 March 2026 and a constitutional law in force since 25 July 2026 set up the Tashkent International Commercial Court, which hears disputes within the Tashkent International Financial Centre and other disputes that parties refer to it in writing. Within the Centre the common law of England and Wales applies, subject to the parties' choice of law.

Two further terms are imposed on the importer by Uzbek rules and sit outside the parties' negotiation. The import contract must be recorded, with its invoices and acts, in the E-kontrakt foreign-trade information system under a 2020 Cabinet of Ministers resolution, and without that record the Uzbek side cannot pay the supplier or clear the goods. A 2026 law-firm memo notes that parties often make registration a condition for the contract taking effect.

Current payments for imports are free of restrictions, but under the currency law an importer that has prepaid must receive the goods or a refund within 180 days. Once a further 45 days have passed, or 90 days for a small business, fines start at 5% of the unrepatriated amount and rise in steps with the delay. The principal's delivery schedule thereby becomes part of the distributor's currency compliance, an effect of how the rules operate that no provision spells out.

The agreement cannot by itself protect a territory against genuine products bought elsewhere. Since 2017 the trademark law has provided that using a mark on goods put on the market by the owner or with its consent is not an infringement, without saying where that first sale must happen. A June 2026 law-firm review of parallel imports found the provision read in opposite ways by different authorities. A July 2026 report on an appellate ruling of the economic chamber of the Tashkent city court describes a decision that applied national exhaustion, banned further parallel imports of a beverage producer's goods and ordered them destroyed. The outlet also cites Supreme Court acts in line with that reading, and its earlier analysis reports a Ministry of Health letter of 13 March 2026 that sets out safety concerns about parallel imports of medicines.

The right to act belongs to the trademark owner, and so do the records that make it effective. The owner can record the mark in the customs register kept by the State Customs Committee, and since 2024 customs may suspend a suspect consignment on its own initiative for up to 10 working days, as the June 2026 review reports. The trademark law has no specific rule on marks filed by an agent or representative. The remedy that the available sources point to is the general ground of unfair competition, under which a registration can be invalidated at any point in its term since an amendment of February 2024. Protection against parallel imports rests on the principal's own registrations, which the distributor's exclusivity cannot replace.

What the State's Digital Records Show About a Distributor's Sales

A contract can oblige the distributor to report on its sales, and the records now required by law give those reports a documentary base. Over six years the state has built an electronic trail of commercial sales that runs from the invoice to the retail receipt. Electronic invoices are compulsory for all businesses under a 2019 Cabinet of Ministers resolution, and in 2025 more than 3.5 m were being issued each month, according to the head of the Tax Committee. Each line of an invoice and of a cash receipt carries a 17-digit product code from the national catalogue, under rules updated in April 2025, so the record names the product as well as the parties. A presidential decree of September 2025 also provides for risk scoring of electronic invoices from 1 January 2026, as the same report notes.

The movement of goods and retail sales are recorded electronically as well. Electronic waybills are mandatory under a Cabinet of Ministers resolution of December 2023, and online cash registers are compulsory for all businesses under a 2019 presidential decree. Tax Committee data show more than 702.6 m online receipts issued in January to August 2024 alone, a measure of the retail transactions now visible to the tax authority.

Digital marking closes the gap between warehouse and shelf for the categories it covers. The national marking system, Asl belgisi, set up under a 2020 Cabinet of Ministers resolution, has become mandatory group by group. By May 2025 about 3,600 producers and importers were registered in it and 8.2 bn units had been marked, as reported by the business press.

Under the May 2025 resolution, a cash receipt for a marked product can now be generated only after its code is entered, and an electronic invoice without the code is not permitted. The same act requires wholesale trade in marked goods to be settled by bank transfer. Under a January 2026 resolution, the system checks automatically, when an invoice is issued, that the seller holds any required licence and is registered for marking. Where marked goods are sold on commission, the commission agent enters the codes, as a news report on the resolution describes. Since 1 March 2026, under an October 2025 act, the sale of products past their expiry date has also been restricted automatically.

Source: Cabinet of Ministers resolutions 522, 737, 149 and 23, Presidential Decree UP-5813, Presidential Resolution PP-190 and reporting on the waybill resolution.

Medicines show how quickly a category becomes traceable once marking starts. The industry round table cited earlier reported that the number of marked medicine packages rose from 107.6 m in 2023 to 595.7 m in 2024. In the state's system each package can then be followed from the aggregated code in the importer's customs declaration through the invoices of each wholesaler to the pharmacy receipt.

Access to these records follows the taxpayer that created them. A Tax Committee service reported in August 2026, called Suspicious situations, shows a registered participant in its online account the sale of its products by other entities, sales through duplicate codes, sales of marked goods without codes and stock past its expiry date. Marking codes are issued to importers and manufacturers, and for medicines also to a foreign holder of the registration certificate that has obtained a non-resident tax number, so it is these participants who see their products in the service. What a foreign brand owner without that status can see is not described in any source located, which marks the limit of the evidence.

For a principal, the value of this trail depends on what the agreement obliges the distributor to hand over. An agreement can require the distributor to reconcile its sales reports against extracts from its electronic invoices, waybills and marking account, which show buyers, regions, timing and stock more precisely than any public statistic. Whether a foreign principal can obtain its own access to the underlying state systems or to the distributor's taxpayer account is a separate question, and the sources reviewed establish no route for it beyond the participant status described above. No public dataset shows sales by brand, so the principal's view of the market runs through what its distributor provides. Outside the marked categories, which exclude most industrial and building products, the trail consists of invoices, waybills and receipts that identify the product type through its catalogue code but cannot follow an individual unit.

Replacing a Distributor in Uzbekistan and the Permissions That Stay Behind

The records in the distributor's name also decide what happens when it is replaced, and the contract is only one of the things that end. Declarations and certificates of conformity are issued in the applicant's name under the law on technical regulation, in force since 29 August 2023, and no provision for transferring such a document to another company appears in the texts reviewed. A United States government guide puts the validity of certificates at up to three years. A new importer consequently needs its own documents where the outgoing distributor was the applicant, while documents held by the manufacturer or its representative create no such dependence. This follows from how the documents are issued, since no rule addresses the point expressly.

A route adopted in June 2026 may reduce that dependence. Under a Cabinet of Ministers resolution of 24 June 2026, goods can be imported on the basis of foreign conformity documents through an application to customs, although its text and effective date could not be confirmed. Where the route applies, the evidence of conformity would, on the reported procedure, rest on the manufacturer's own foreign documents.

Digital marking ties a product to an importer in a similar way. Importers and manufacturers issue the codes, and goods cannot be released for free circulation unless the customs declaration carries their aggregated import code, under the core marking resolution. For medicines, codes can also be ordered by the foreign manufacturer or the holder of the registration certificate, which may obtain a non-resident tax number for that purpose under a separate resolution. A product card in the system requires a Global Trade Item Number (GTIN), and an importer may use the manufacturer's existing foreign number. No rule on transferring a product card between importers was found in the system's guidance for importers or in the marking resolutions.

Medicines show where the line falls between the product and the right to sell it. Under a presidential decree of August 2025, a registration certificate is issued in the name of the rights holder or the manufacturer for five years, and since 1 October 2025 medicines registered by regulators on the World Health Organization's list can be registered by recognition. A change of distributor leaves the medicine registration itself untouched. The right to sell to the trade moves with the importer, because imported medicines reach wholesalers and pharmacies only through the importer or its official dealers under the May 2025 resolution.

Price registration and licences follow the company that filed for them. Prices of medicines are registered by the certificate holder or its authorised representative under a 2019 resolution on price regulation, so the position after a change depends on who filed, and a pharmaceutical licence stays with the company that holds it. Alcohol wholesale is licensed company by company, and no route for transferring such a licence to a successor distributor was identified. Under a law of 27 November 2025, in force since 1 March 2026, non-resident companies may apply for licences and permits only through a permanent establishment registered in Uzbekistan, with exceptions for one-off foreign-trade and transit permits. A foreign principal therefore cannot hold a wholesale licence without a local presence.

Most permissions follow the importer, while medicine registrations stay with the manufacturer

Records and permissions affected by a change of distributor, position on 25 September 2026

Source: Law on Technical Regulation, Law ZRU-844, Law on Trademarks, Cabinet of Ministers resolutions 283, 737 and 149, Presidential Decree UP-137 and Presidential Resolutions PP-190 and PP-4554.

Because invoices for marked goods are now checked automatically for the required licence, a gap between the outgoing distributor's licence and the new one's would stop shipments in a licensed category, which is an inference from how the check works. The import channel has to be rebuilt as well, because a new supply contract needs its own record in E-kontrakt before the new importer can pay for or clear goods. Stock already in the outgoing distributor's warehouse carries codes issued through its account and remains lawful to sell, which the marking rules imply without stating it. Whether the outgoing distributor could later bring in genuine goods from abroad depends on the trademark owner's rights discussed earlier, which on the July 2026 appellate reading allow the owner to stop such imports.

The contractual exit is the shorter part of this sequence, since a supply relationship ends on its written terms or for material breach and a commission can be ended by the principal at any time with notice. A case from another market in the region illustrates the point, although it is no benchmark for Uzbekistan. In a Tretiakov Consulting mandate in Azerbaijan, a consumer brand replaced an exclusive distributor that had become a wholesale intermediary with two direct partners and a local representative, and the handover ran through a defined wind-down period. In Kazakhstan the rules of the Eurasian Economic Union apply regional exhaustion of trademark rights, which changes the parallel-import question discussed in the distributor question in Kazakhstan.

What Is Already Decided for Distribution in Uzbekistan to 2031

The changes that matter here are those that could move records between the importer and the principal, and the largest open question among them is accession to the World Trade Organization (WTO). By the 13th meeting of the accession working party in late July 2026, 31 of 34 bilateral market-access agreements had been lodged with the WTO Secretariat, and members noted that some legislation was being adopted more slowly than expected, according to business press reporting. The President's office has set full membership in 2026 as the target, and an EU document of February 2026confirms that Uzbekistan's services offer includes wholesale and retail distribution. The detailed commitments on distribution services and on the right to trade have not been published, so whether accession would change the rule that gives the right to trade across the border to locally registered entities cannot be established from the documents available.

Conformity assessment is the area most likely to change the documents a distributor holds. The President's office reported in May 2026 that mandatory certification had already been removed for 747 product items, and a presidential decree of 16 February 2026 made standards voluntary and provides for a national conformity mark with risk-based assessment. Under that decree products covered by technical regulations are to be removed from the list requiring mandatory assessment, and the June 2026 resolution on foreign conformity documents works in the same direction. If fewer products need an Uzbek certificate or declaration, fewer papers will be issued in an importer's name, although the combined effect on what distributors hold cannot be measured from published data.

Marking, by contrast, will widen the records held in an importer's name. The fourth group of medicines and medical devices and dietary supplements are due to join the system under a January 2026 resolution and a March 2026 decree. Vegetable oil has entered a pilot, with a mandatory start still at the planning stage according to press coverage of that resolution. A draft published in July 2026 would add jewellery, so the share of sales that leave a unit-level record in an importer's account will grow. For medicines the August 2025 decree adds requirements for certified manufacturing and quality systems, which apply to the manufacturer and leave the allocation of the registration unchanged.

Dated measures to 2031 concern product documents and marking, while two reforms remain drafts

Measures affecting distribution in Uzbekistan by status, position on 25 September 2026

Source: Presidential Decrees UP-25, UP-35 and UP-137, Cabinet of Ministers resolutions 23 and 149, reporting on Resolution 324 and the jewellery draft, and reporting on the beneficial-ownership draft and the Civil Code draft.

The forum for distribution disputes is set to widen within the period. The Tashkent International Commercial Court is expected to launch in full in the second half of 2027 or in 2028, according to a professional services review reported by the business press. That is an expectation that no act has yet fixed, and until then international arbitration remains the tested route. The two reforms that would most change the evidence available on a distributor, the open register of beneficial owners and the new edition of the Civil Code, remain drafts with no published adoption date.

Market growth gives the other half of the outlook. If nominal wholesale turnover keeps the pace of January to August 2026, when it was 23.6% above the restated figure for January to August 2025, the full year would reach about UZS 719 trn (Tretiakov Consulting calculation). The 2026 series was restated partway through the year, and depending on which seasonal profile is applied the estimate moves by about 12%.

Goods imports grew by 18.5% in January to July 2026 and at that pace would reach about USD 49.9 bn for the year (Tretiakov Consulting calculation). No published forecast of wholesale turnover beyond 2026 was found, so the outlook to 2031 rests on the adopted measures in the table. Apart from the new route for foreign conformity documents, none of those measures moves the import record or the marking account from the importer to the principal, which is an interpretation of the texts as published.

What Decides Control Over the Market

Before signing, Uzbekistan's public records can establish a candidate's legal existence, registered founders, tax conduct, history with state customers and any designation on a sanctions list. They cannot establish its ultimate owner or its capacity, which rest on the candidate's own disclosures. They show which products it already handles only where it appears as an applicant for conformity documents or holds a licence in a regulated category. The Civil Code leaves targets and exit largely to the wording of the agreement, and the 2023 competition law limits the restrictions a principal can place on a distributor's resale. After signing, the state's electronic records make a distributor's sales traceable from import to receipt, but they sit in the distributor's account and reach the principal only as extracts that the agreement obliges the distributor to provide.

At exit, the import record, the conformity documents in the distributor's name, its marking account and its licences stay with it. Papers held by the manufacturer stay with the manufacturer, including medicine registrations, which are granted to the rights holder or producer, although in pharmaceuticals the right to sell to the trade still follows the importer. The measures adopted to 2031 add marked categories and may reduce the conformity documents issued to importers, but none of them transfers these records to the principal. The difference between one distributor in Uzbekistan and another therefore lies less in the terms it accepts than in whose name the import contract and the product documents are issued, and that allocation is settled before the first shipment.

Tretiakov Consulting supports foreign companies on partner models, risk assessment and operating set-up in Uzbekistan. Discuss your distribution in Uzbekistan.