Uzbekistan Electronics Labeling Reform: The CUz Conformity Mark and the Road to 2027
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Understanding the CUz Conformity Mark in Uzbekistan's Regulatory Reform
Uzbekistan's electronics compliance landscape is undergoing a fundamental transformation. At the center of it is the CUz conformity mark, short for Conformity Uzbekistan, a national marking that will become mandatory for all products subject to technical regulations starting January 1, 2027. For electronics manufacturers exporting to Central Asia, this is one of the most consequential regulatory shifts of the decade.
The official authority overseeing this transition is the Uzbek Agency for Technical Regulation (ATR), established under Presidential Decree No. PF-41 of February 27, 2024, and now operating directly under the Cabinet of Ministers. All technical regulations and drafts regulations are published on the Government Portal of the Republic of Uzbekistan at gov.uz, which serves as the primary official source for compliance updates.
What the CUz Mark Actually Means
The CUz mark is not simply a label. It is a legal declaration that a product has undergone conformity assessment, whether through a Declaration of Conformity (DoC) or a full Certificate of Conformity issued by an accredited Conformity Assessment Body (CAB) and meets the requirements of applicable Uzbekistan technical regulations, including safety, electromagnetic compatibility (EMC), and hazardous substance restrictions.
Under the revised system, the CUz national conformity mark will be applied to products subject to technical regulations from January 1, 2027, and a draft resolution detailing the precise rules and conditions for its use is currently under consideration.
The mark connects the physical product to the official documentation and to Uzbekistan's market surveillance infrastructure. It is not interchangeable with the CE mark or any other regional conformity symbol, and manufacturers cannot assume equivalence.
The Regulatory Foundation: RoHS, Technical Regulations, and the ATR
On August 15, 2025, the Cabinet of Ministers approved Resolution No. 517, a Technical Regulation restricting the use of hazardous substances in electrical and radio-electronic products. This move supports the implementation of Presidential Resolution No. PP-91, which establishes the Agency for Technical Regulation and sets unified safety standards across the sector.
The Uzbekistan RoHS regulation restricts the use of specific hazardous substances in new electrical and electronic products placed on the market, covering a broad scope that includes light sources, lighting equipment, power supplies, chargers, cables rated up to 500V, and fire and security alarm systems.
Due to widespread concern about the feasibility of meeting the original February 16, 2026 deadline, the Cabinet of Ministers postponed the start of obligations by 12 months to February 16, 2027 a significant win for manufacturers that allows more time to align technical documentation and substance restrictions with the new standards.
Regarding exemption alignment, manufacturers should proceed with caution: Uzbekistan maintains its own exemption list and has not mapped EU RoHS exemptions to its own regulation, so it is unsafe to assume that an exemption valid in the EU also applies in Uzbekistan.
Digital Labeling: A Parallel System Running Alongside CUz
In addition to the conformity mark, Uzbekistan operates a mandatory digital labeling (traceability) system for a defined list of household appliances. These are two distinct but interrelated compliance layers.
Mandatory digital labeling remains in force for gas stoves, central heating boilers, residential and industrial air conditioners, refrigerators and freezers, washing machines, vacuum cleaners, juicers, mixers, water heaters, televisions, and monitors. Certain lighting and electronic components have also been added, including sealed directional lamps, LED modules, and electronic lamps and tubes.
Nine categories of electrical appliances have been excluded from the digital labeling requirement, including phones and smartphones, radios, electronic scales, electric shavers, dishwashers, microphones, and audio recording equipment.
Starting March 1, 2026, a new procedure for the sale of digitally labeled goods was introduced: once a product's expiration date passes, the digital labeling system automatically blocks its sale, and the online point-of-sale system will not allow a receipt to be printed for that product.
Until August 1, 2026, Uzbekistan's Tax Committee will introduce proposals to regulate the mandatory seizure of counterfeit products and goods with fake digital markings, with criminal liability imposed for the production, import, or sale of such goods.
Certification Impact Summary
Aspect | Detail |
Mark Name | CUz (Conformity Uzbekistan) |
Mandatory From | January 1, 2027 |
RoHS Deadline | February 16, 2027Aspect |
Governing Body | Agency for Technical Regulation (ATR) |
Assessment Types | Declaration of Conformity (DoC) or Certificate of Conformity |
Certificate Validity | Up to 3 years for mass-produced products |
EU Exemptions Valid? | No — Uzbekistan exemptions are independent |
Official Website | |
Digital Labeling | Parallel mandatory system for specific appliance categories |
The conformity mark may only be used in conjunction with a certificate for serial production, which has a 3-year validity period. The conformity assessment procedure in this case requires factory inspection control and annual surveillance.
Conformity assessment in Uzbekistan is carried out by accredited Conformity Assessment Bodies (CABs), and only products placed on the market in Uzbekistan are subject to mandatory conformity confirmation. The list of such products is governed by Cabinet of Ministers Resolution No. 43 dated January 30, 2021.
What This Means for Manufacturers
The CUz reform is not a bureaucratic footnote it is a structural change in how Uzbekistan manages product safety and market access. Manufacturers selling or planning to sell electronics in Uzbekistan should expect the following practical implications:
1. No automatic transfer from CE or other marks. The CUz mark requires independent conformity assessment under Uzbekistan's own technical regulations. A CE-marked product is not automatically CUz-compliant.
2. New documentation requirements. Technical documentation must be prepared and registered in accordance with Uzbekistan ATR requirements. This includes test reports, declarations of conformity, and product-specific technical files.
3. Substance restrictions go beyond labeling. The RoHS technical regulation restricts ten hazardous substances with defined concentration limits. Manufacturers must verify their bill of materials and supply chain against Uzbekistan's specific substance list not the EU's.
4. Digital labeling is a separate obligation. If your product falls within the mandatory digital labeling list (appliances, televisions, lighting, etc.), you must also register with the CRPT Turon LLC traceability system, which is Uzbekistan's government-designated partner for digital marking.
5. Market surveillance is being strengthened. Uzbekistan is actively expanding its enforcement capacity, with the ATR submitting quarterly implementation reports to the Cabinet of Ministers and criminal liability being introduced for fake or counterfeit labeling.
Timeline and Required Actions
Now through Q3 2026
Review your product portfolio against Uzbekistan RoHS and the mandatory digital labeling list
Conduct internal gap analysis on hazardous substance concentrations
Identify applicable Uzbekistan technical regulations through gov.uz
Select an accredited Conformity Assessment Body (CAB) in Uzbekistan
Q4 2026
Prepare and submit technical documentation for conformity assessment
Complete product testing against applicable Uzbekistan standards
Register digital labeling obligations with CRPT Turon LLC if applicable
January 1, 2027
CUz conformity mark becomes mandatory on all regulated products
Products entering the market without valid conformity documentation may be blocked or seized
February 16, 2027
Full enforcement of Uzbekistan RoHS substance restrictions begins
Certificates of Conformity must be in place for all regulated EEE categories
