The country of origin of the goods in purchases under 223-FZ: what is important to know in 2025

The Ministry of Finance and the Federal Antimonopoly Service continue to tighten control over the indication of the country of origin of goods in purchases under 223-FZ. We analyze the key requirements and innovations. Where is it necessary to indicate the country of origin? In contracts – for the supply of goods, as well as in contracts for works/services, if goods are supplied within their framework (Part 5.2 of art. 3 223-FZ). In the register of contracts, the information must match the data from the contract. In the procurement documentation, if it is provided for in the procurement regulations. Important: The data must comply with the All-Russian Classification of Countries of the World (OCSM). If the product is from the EAEU, specify the specific country of origin (Belarus, Kazakhstan, etc.). How do I require confirmation from suppliers? Include the condition in the purchase regulations (part 2 of art. 2 223-FZ). Write it down in the documentation: The requirement to indicate the country of origin in the application (clause 12, part 19.1, Article 3.4, 223-FZ). The possibility to request a documentary confirmation (CT-1 certificate, manufacturer's declaration). An example of the wording: "The participant is obliged to indicate the country of origin of the goods in accordance with the OKSM. At the request of the customer, provide supporting documents (for example, a certificate of the ST-1 form)." What should I do if the participant provided incorrect information? To refuse to conclude a contract (if the fraud was discovered at the stage of reviewing applications). Terminate the contract and collect damages (if the inaccuracy is revealed after signing). Include the supplier in the register of unscrupulous persons (if the violation is confirmed by the decision of the Federal Antimonopoly Service). Tip: Write down penalties for false information in the contract — this will reduce the risks.