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Supplying Goods from China to Uzbekistan in 2026: Foreign Trade Contract, Customs, Certification and Currency Control

Goods from China enter Uzbekistan through a resident importer under a contract meeting Resolution No. 283 and registered in E-kontrakt. China has MFN status, but since 28 February 2026 goods without a certificate of origin pay an additional 5–20% duty.

Pactum Legal Team
Pactum Legal Team
Pactum Corporate Practice
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Goods from China can be supplied to Uzbekistan safely only through an Uzbek resident importer: it signs a foreign trade contract containing the mandatory sections set by Cabinet of Ministers Resolution No. 283 of 14 May 2020, enters it into the E-kontrakt system, declares the goods with a documented customs value and makes sure that goods paid in advance are cleared within 180 days. China is on Uzbekistan's most-favoured-nation (MFN) list, so Chinese goods pay the base tariff rates, but only if their origin is proven: without a certificate of origin, an additional duty of 5% to 20% applies from 28 February 2026. Everything below is stated as of October 2026.

Key points

  • A resident imports. Under Regulation No. 283 the importer is a legal entity or individual entrepreneur resident in Uzbekistan. A Chinese factory needs a buyer, a distributor or its own subsidiary.
  • The contract is checked twice. The bank checks E-kontrakt data before a prepayment or letter of credit; customs checks it before clearing the declaration.
  • Language. A contract in Chinese, Russian or English must be translated into the state language (Uzbek) and the translation certified.
  • 180 days for prepaid goods. Goods must be cleared for import within 180 days of payment; the fine starts 45 days later, or 90 days later for small businesses.
  • Origin is money. Without a certificate of origin, the additional duty under Article 300¹ of the Customs Code applies; the certificate can still be filed within one year.
  • Post-clearance audit is possible for three years.

Who can import

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The Regulation on the Procedure for Monitoring and Control of Foreign Trade Operations (Annex No. 1 to Resolution No. 283) defines importers as legal entities and individual entrepreneurs resident in Uzbekistan that have signed a contract or invoice with a non-resident (para. 2). They carry the duties to enter data into the system and to repatriate assets. A resident settles under the contract only through its account with an Uzbek bank, unless the law provides otherwise (para. 16).

For a Chinese exporter this means three models: selling to an Uzbek buyer, appointing an exclusive distributor under a framework agreement (territory, purchase targets, brand, after-sales service), or setting up its own subsidiary, which becomes the importer itself.

Mandatory sections of a foreign trade contract

Paragraph 4 of Regulation No. 283 sets the minimum requirements. A Chinese supplier's standard template usually does not cover them, and such a contract runs into problems both in the system and at the bank.

Section (para. 4)What it must contain
(a) PreambleNumber, place and date, full names of the parties, signatories; the representative's power of attorney. If another company pays or ships (for example, a trading company instead of the factory), it is named separately
(b) SubjectName, characteristics, quantity and quality, standards, model, brand, certificate of conformity if any, HS (TN VED) code; for equipment, whether new or used
(c) Delivery basisIncoterms with the place of delivery (station, port, airport)
(d) Delivery termsFinal delivery dates and deadlines
(e) Amount and priceTotal amount and unit price by HS unit; for equipment, installation, commissioning, training and royalties stated separately
(f) PaymentCurrency, form and timing; if the payment currency differs from the contract currency, the conversion rate and its source
(g) OriginCountry of origin and manufacturer
(h) LiabilityPenalties and/or fines
(i) DetailsPostal, bank and shipping details
(j) BarterAdvance delivery or counter-guarantees
(k) LanguageThe state language, or another language with a certified translation into the state language

Changes are made only by a supplementary agreement and entered into the system in the same way as the contract (para. 5); changing terms, including the goods, without one is prohibited (para. 11). A new price agreed in a messenger chat does not exist for the bank or customs. Importing on an invoice without a contract is also allowed once the data is entered into the system (para. 6), but for regular supplies a full contract is safer.

Registration in E-kontrakt

Businesses, except self-employed persons, enter data on contracts, acts and invoices with an electronic digital signature into the E-kontrakt foreign trade information system of the Customs Committee under the Ministry of Economy and Finance (para. 1 of Resolution No. 283; in places the Regulation also calls it EEISVO). On the public services portal this is service No. 96.

  • The bank compares system data with the contract before a prepayment or a letter of credit and executes the operation only if there is no discrepancy (para. 11).
  • Customs compares the contract and invoice data in the system with the declaration (para. 14).
  • Incorrect data is treated as a breach of the procedure for export-import operations and leads to liability (para. 6).

If an Uzbek buyer says the bank "won't release" the prepayment, a common reason is that the contract is not in the system or its data does not match the invoice.

Customs value and classification

Value

The primary method is the transaction value; if it cannot be used, the methods based on identical goods, similar goods, deduction, computation and the fallback method apply in sequence (Art. 302 of the Customs Code). The following are added to the price if not already included (Art. 304): delivery to the place of import into Uzbekistan, with insurance and handling; the buyer's brokerage and commission fees (other than buying commissions) and packing; raw materials, tools, moulds, design and drawings that the buyer supplied to the manufacturer at its own expense or at a reduced price; and licence fees for intellectual property payable as a condition of sale. For Chinese factories this mainly means tooling paid for separately by the buyer and brand royalties.

Customs may reject the method if there are no supporting documents, if requested documents are not filed, or if there are signs that they are unreliable (Art. 319); if the value cannot be determined, conditional release against payment or security is possible (Art. 321). The evidence is gathered before filing: the export declaration of the country of dispatch, the manufacturer's price list, proof of payment and transport costs shown separately.

Classification

The HS code determines the duty rate, certification requirements and restrictions. Customs may issue an advance classification ruling; it is binding on customs authorities (Art. 370 of the Customs Code) and is valid for one year unless amended, withdrawn or revoked (Art. 372). The request gives the commercial name and characteristics and, where needed, photos, drawings and product passports (Art. 371). For regular supplies, get the ruling before the first shipment.

Post-clearance audit

Post-clearance control and additional assessment of payments are possible within three years after the goods leave customs control, and no more than once per contract (Art. 201). A complaint against a decision issued after an audit goes to the higher customs authority within one month of the day the person learned or should have learned of the breach of its rights (Art. 409²).

Duty, VAT and other payments

On import, customs duty, VAT, excise tax (for excisable goods) and customs fees are payable (Art. 289), before or at the time the declaration is accepted (Art. 327).

  • Duty may be ad valorem, specific or combined (Art. 293). We determine the rate from the code in the current tariff and do not quote it here because it differs for each tariff line. Special, anti-dumping, countervailing and seasonal duties may also apply (Art. 290).
  • VAT is 12% (Art. 258 of the Tax Code); the import base is customs value plus duty and excise (Art. 254); on release for domestic use the tax is charged in full (Art. 277).

Origin: China and MFN treatment

Since 28 February 2026, Article 300¹ of the Customs Code (Law ZRU-1097 of 27 November 2025) applies: tariff rates apply to goods originating in MFN countries regardless of the country of dispatch, while goods from other countries or of unknown origin pay an additional duty.

The People's Republic of China is on the list of states granted MFN treatment (reg. No. 3267 of 30 June 2020). China is not on the list of states with an FTA regime, so there is no zero-duty treatment under a trade agreement for Chinese goods.

Base ad valorem rateAdditional duty (Art. 300¹)
up to 10%5%
10% to 20%10%
20% to 30%15%
30% and above20%

Under Article 366, a missing certificate of origin does not block release, but without it, or if it is doubtful, the additional duty applies. MFN treatment is restored if a proper certificate is filed within one year of placing the goods under a duty-paying regime; the overpayment is refunded under Chapter 49 of the Code. The certificate is issued by the authorised body under the rules of the exporting country (Art. 363), and customs may ask that body for clarification (Art. 364). The country and manufacturer in the certificate must match the contract. Duty depends on the country of origin, not of dispatch: third-country goods shipped from China do not become Chinese.

Certification and technical regulation

Mandatory conformity assessment is set by technical regulations and takes the form of a declaration of conformity or mandatory certification; both have equal legal force (Arts. 23–24 of the Law "On Technical Regulation" ZRU-819). A declaration may be adopted by the manufacturer, its authorised representative, the seller or the importer (Art. 26). The importer must place only compliant products on the market and ensure that the manufacturer has carried out conformity assessment, prepared technical documentation and applied the conformity mark (Art. 44).

Whether a certificate or a declaration is needed depends on the code and the applicable regulation and is checked before the contract. The contract with the factory should oblige it to hand over technical documentation, test reports and labelling.

Payment and currency control

A resident must ensure repatriation of assets (Art. 11 of the Law "On Currency Regulation" ZRU-573); for imports this means the goods arriving and being cleared, or the money being returned (para. 27 of Regulation No. 283). Goods must be cleared for import within 180 days of payment (para. 23). The fine under Article 11¹ of ZRU-573 applies if assets are not repatriated more than 45 days after the 180 days from payment have expired (90 days for small businesses):

Delay from the payment dateFine to the budget
up to 360 days5% of the unrepatriated amount
360 to 545 daysadditional 10%
over 545 daysadditional 35%

The fine does not apply during the delivery period of equipment and components under contracts with a delivery term over 180 days due to their technical features, or where government bodies destroyed or confiscated goods that became unusable in transit or storage for reasons beyond the parties' control (confirmed by a document of the competent authority); force majeure extends the deadline. The tax authority sends the demand, and the company replies within 10 days (para. 28 of the Regulation). If the fine is paid voluntarily within 10 days and assets are repatriated within 90 days, it is refunded proportionally (Art. 11¹).

How to choose payment terms:

  • Prepayment suits the exporter, but production and delivery must fit within 180 days with a margin.
  • A letter of credit is opened after checking E-kontrakt and protects both sides.
  • Deferred payment removes the 180-day risk for the importer but shifts credit risk to the exporter; cover it with a guarantee or insurance.
  • Renminbi is allowed: the payment currency is agreed by the parties (para. 4(e)).

Consequences of breaches

  • Defective contract or missing from the system: the bank does not execute the payment (para. 11), and customs checks the system data against the declaration (para. 14); administrative liability of officials is set by Art. 171 of the Code of Administrative Responsibility.
  • Overdue prepayment: up to 50% of the amount in total (Art. 11¹ of ZRU-573).
  • Wrong value or code: additional duty and VAT within three years (Arts. 201 and 320 of the Customs Code).
  • No certificate of origin: additional duty of 5–20%.
  • No conformity assessment: the importer breaches Art. 44 of ZRU-819, which obliges it to place compliant products on the market and ensure that conformity assessment has been carried out.

Building a presence in Uzbekistan

FormWhat it can doLimits
DistributorImports and sells in its own namePrice and brand control only by contract
Representative officeRepresents the head company and negotiatesNot a legal entity and does not carry out economic or commercial activity (para. 7 of the Regulation approved by CM Resolution No. 76 of 7 February 2024), so it cannot be the importer
Subsidiary LLCBecomes the importer itself, runs the warehouse and salesFull accounting, tax and currency control

The application for accreditation of a representative office is filed through a public services centre or the Single Portal of Interactive Public Services (paras. 6 and 9 of Regulation No. 76). More on structures: company formation in Uzbekistan.

Check a distributor before signing: registration data by taxpayer number is available through public service No. 77 (data from the Ministry of Justice and the Tax Committee), while the real capacity to perform is checked by requesting documents and an on-site check; see counterparty due diligence. For disputes, international arbitration works well: both China and Uzbekistan are parties to the 1958 New York Convention, China with reciprocity and commercial-dispute reservations.

Typical mistakes

  • The supplier's template contract: no HS code, place of delivery, manufacturer or translation; it runs into problems in the system and at the bank.
  • Changing the price in chats: without a supplementary agreement, contract, invoice and declaration diverge.
  • Prepayment for long production: over 180 days without the equipment exception leads to overdue repatriation.
  • No certificate of origin: Chinese goods pay the additional duty.
  • Forgetting tooling and royalties: they form part of customs value (Art. 304) and surface during audits.
  • Choosing the code by its rate: the error repeats across three years of shipments.
  • Trading through a representative office: it may not carry out commercial activity.

Shipment checklist

StepWhoResult
Buyer checkExporterTaxpayer data, documents, risk conclusion
Code and regulationImporterRate, certificate or declaration, advance ruling if needed
Contract under para. 4Both partiesSigned contract and translation into the state language
E-kontraktImporterData with digital signature before prepayment or L/C
PaymentImporterVia an Uzbek bank; 180-day calendar
ShipmentExporterInvoice, packing list, transport documents, certificate of origin, export declaration
DeclarationImporter or brokerValue under Art. 304, payment of duty, VAT and fees
ChangesBoth partiesSupplementary agreement entered into the system
ArchiveImporterDocument set kept for three years

FAQ

Can a Chinese company import goods itself?

The importer is an Uzbek resident. A Chinese company sells to an Uzbek buyer or sets up a subsidiary; a representative office will not work because it may not carry out commercial activity.

Does the contract have to be in Uzbek?

It can be in any language, but its translation into the state language must be certified in the prescribed manner (para. 4(k) of Regulation No. 283).

Can we be paid in renminbi?

Yes, the payment currency is agreed by the parties; if it differs from the contract currency, the rate and its source are stated. Payment goes through an Uzbek bank after the E-kontrakt check.

Is there a China–Uzbekistan FTA?

China is not on the FTA list; it is on the MFN list, so base rates apply once origin is proven.

What happens without a certificate of origin?

The goods are released but pay an additional duty of 5–20% (Arts. 300¹ and 366). File the certificate within one year and the overpayment is refunded.

How long does the importer have after a prepayment?

180 days from payment (para. 23 of Regulation No. 283), then another 45 days (90 for small businesses) before the fine.

How do we challenge a customs valuation?

Through consultations with customs and a request for a written explanation of the reasons (Art. 319), then a complaint to the higher customs authority or to court (Arts. 320 and 409¹). If the value was adjusted after an audit or customs audit, the complaint to the higher authority is filed within one month (Art. 409²). Documents gathered before the declaration decide the case.

How Pactum helps

Pactum is a law firm in Tashkent (PACTUM-AI CA LLC). For supplies from China we draft the contract under para. 4 of Regulation No. 283 and support its entry into E-kontrakt, review the supplier's contract, determine the code and build the customs value file, keep the prepayment deadline calendar, check the distributor and register the subsidiary.

Indicative fees: foreign trade contract from 4,000,000 UZS, contract review from 2,000,000 UZS, company registration from 1,500,000 UZS. The final fee is fixed in a written proposal after reviewing the task; state fees and third-party costs are extra.

More on the practice: foreign trade, customs and currency control. Book a consultation online, call +998 99 050 50 70, write on Telegram @pactumcrmbot or email info@pactum.uz.

Sources

Uzbek acts are cited from lex.uz; quotations are our translation or summary. The information is current as of October 2026 and is not individual advice.

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Foreign trade, customs and currency control in Uzbekistan

A foreign trade contract that clears both the system and the bank, compliance with repatriation deadlines, and defence in disputes over customs value and classification.

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Pactum Legal Team
Pactum Legal Team
Pactum Corporate Practice

The Pactum legal team supports businesses in Uzbekistan: company registration and structuring, tax disputes, M&A, licensing and foreign-trade matters.

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