The Proposed Ban on Mixed Procurement Lots
The Russian Ministry of Industry and Trade has drafted amendments that would forbid state customers from combining electronics with different import-substitution regimes into a single procurement lot. Under current practice, a government agency can package together devices for which a Russian analogue exists—and is listed in Minpromtorg's domestic equipment registry—alongside equipment with no local alternative. In such mixed lots the 'second extra' rule, which normally blocks the purchase of foreign goods when a Russian-made substitute is available, does not apply. The result is that foreign electronics can be bought across the whole contract.
The draft government decree, set to come into force on 1 January 2027, amends Resolution No. 1875 of 23 December 2024. It establishes a strict national regime for procurements under federal laws 44-FZ and 223-FZ. Goods are split into three lists: an outright ban on foreign items (first list), restricted admission where a Russian alternative exists (second list), and a 15% price advantage for Russian products that fall outside those lists.
How the Loophole Worked and What Its Closure Changes
The Mixing Trick That Bypassed 'Second Extra'
By combining compliant and non-compliant items in one tender, procurement officers effectively neutralised the 'second extra' mechanism. Because the lot contained at least one good with no domestic analogue, the entire lot was treated as having no suitable Russian option, opening the door to foreign suppliers for every piece of equipment. This loophole has been a persistent complaint from Russian electronics manufacturers, who argued they were being shut out of state contracts despite having registered products.
A Boost for Russian Manufacturers, A Setback for Foreign Suppliers
The change will make the 'second extra' rule bite harder: state buyers will have to split out goods that have Russian counterparts and award them separately, where foreign bids will be excluded if a domestic alternative exists. For Russian producers of servers, telecom gear, computer hardware and other electronics, this means a larger, practically guaranteed share of the state market. Foreign vendors, on the other hand, will lose the ability to piggyback on lots where no domestic substitute was available, and will be limited to tenders genuinely lacking a Russian analogue—a shrinking pool as the domestic registry grows.
The Regulatory Architecture Behind the Move
The amendment layers on top of the existing three-tier import-substitution system. The first list already imposes outright bans, the second restricts admission, and the third gives Russian goods a 15% price edge. The new rule prevents procurement officers from mixing categories, effectively enforcing the hierarchy: when a good appears on the first or second list, it must be procured separately under those strict rules, even if other items in the same planned order fall into a looser category.
For Government Buyers and Electronics Firms: Navigating the New Rules
- State procurement departments should immediately audit future tenders: any lot that contains electronics from different import lists will need to be split into separate contracts. Budgeting and planning cycles must build in lead time for this separation, as the ban takes effect from 1 January 2027 under the amended Resolution No. 1875.
- Russian electronics firms can prepare for higher order volumes by verifying that their products are correctly registered in Minpromtorg's domestic equipment list and that they can meet compliance documentation. They should also watch for any tightening of the 'Russian origin' criteria and invest in capacity to avoid supply bottlenecks.
- Foreign suppliers will find that mixed-lot opportunities evaporate. Access to the state market will increasingly require localisation—either full production in Russia or partnerships that allow products to qualify as domestic under the rules tied to the three lists. The remaining route is to focus on niche equipment with no Russian analogue, but that window will shrink as the domestic registry expands.
Risk & Opportunity Assessment
| Commercial Risk | Medium | Foreign electronics suppliers losing mixed-lot state contracts face a measurable revenue hit, but many already have limited exposure to Russian public procurement due to sanctions and earlier import-substitution measures. |
| Competitive Risk | Low | Russian manufacturers gain a defensive moat against foreign rivals in state tenders; the primary internal risk is that they may face stiffer price competition among themselves as the pie grows. |
| Regulatory Risk | Medium | The decree is still a draft and could be softened before final adoption, or its enforcement could be delayed past 2027 if government agencies push back on the operational burden. |
| Reputation Risk | Low | No significant narrative risk: the measure is framed as support for domestic industry and import substitution, aligning with official policy messaging. |
| Technology Disruption | Low | The rule changes procurement mechanics, not the underlying technology; it does not alter product roadmaps or demand for radical innovation. |
| Commercial Opportunity | High | For Russian electronics companies, the closure of the mixed-lot loophole directly expands the addressable state market by forcing separate tenders for goods with domestic analogues, all but guaranteeing demand growth. |
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