Ministry of Finance: registration records on the origin of goods are not required for calculating the NMCC
The Russian Ministry of Finance explained the specifics of the application of a special procedure for the justification of NMCC in procurement with prohibitions and restrictions under Resolution No. 1875.
The Agency confirmed that when determining the identity and uniformity of goods, the customer really should take into account only products originating from the EAEU member States.
It is important that the customer must first request commercial offers through GIS from manufacturers with registered records. And only if such proposals are not received, he has the right to proceed to the general procedure for calculating the NMCC according to art. 22 of Law No. 44-FZ.
However, at the same time, the Ministry of Finance pointed out that Law No. 44-FZ and Resolution No. 1875 do not require confirmation of the origin of goods precisely at the stage of collecting commercial proposals for calculating the NMCC by submitting registry entries (RRPP or EPPP).
Thus, the presence of an entry in the register of industrial products is not a prerequisite for using a commercial offer to justify the initial price, but only after the customer has fulfilled the primary obligation to request prices from manufacturers with the register.