The proposals of the StekloSouz Association of Russia on the implementation of Decree of the Government of the Russian Federation No. 616 of April 30. 2020

Dear colleagues, good afternoon!

As is known, the StekloSouz Association of Russia received a letter asking it to consider a draft order of the Ministry of Industry and Trade of the Russian Federation on the implementation of Decree of the Government of the Russian Federation No. 616 of April 30. 2020

We inform you that having studied this issue in detail, the StekloSouz Association of Russia sent its proposals to D. N. Kurochkin, Vice-President of the Chamber of Commerce and Industry of the Russian Federation.

The draft order provides for the procedure for the Ministry to issue permits for the purchase of industrial goods originating from foreign countries at the request of state customers, and the procedure for the formation and maintenance of the Register.

It seems that the proposed algorithm for issuing permits for the purchase of foreign goods by the Ministry is complex. For example, filing applications (paragraphs 9-10) provides that the responsible department checks the analogue of Russian and Eurasian products. After control, the department sends the application to the manufacturer through the GISP. The draft document does not provide for the regulation of the process in cases where there will be two or more manufacturers of products.

The permit will be valid for 18 months (paragraph 15). It is necessary to reduce the period to 1-2 months. For the specified period, it is possible that the domestic manufacturer will master the production of the required products.

All applications must be considered at the Expert Council (EC) and the Working Group (WG) with the participation of industry experts and representatives of the Chamber of Commerce and Industry of the Russian Federation (RF CCI).

It is proposed that the Register be formed by the Chamber of Commerce and Industry of the Russian Federation; it will be difficult for the Ministry of Industry and Trade of the Russian Federation to independently cope with the task.

The document assumes a complex system for enterprises to be included in the Register, the regional structures of the RF CCI will cope with the task more successfully and without red tape, because know the real situation of enterprises on the ground. At the same time, companies will provide consulting support.

We propose to provide for the creation of an open Register for applications in the order, so that product manufacturers can see the conditions and specific requirements of applicants (except for the military-industrial complex).

We hope that in the proposed version, Decree of the Government of the Russian Federation No. 616 of 04/30/2020 will successfully work for the benefit of the development of domestic industry.

Yours faithfully,

President of the Association "StekloSouz"

Osipov V.I.