New Consumer-Facing Language Rules (1 March 2026) and the Role of Trade Marks

From 1 March 2026, Russia introduced a clearer statutory regime for foreign-language wording used “in front of consumers” outside advertising. Federal Law No. 168-FZ of 24 June 2025 adds Article 10.1 to the Consumer Protection Law (Law No. 2300-1). The rule is drafted broadly and in a media-neutral way: it covers signs and other means of placing information (inscriptions, pointers, plates, signs, constructions, surfaces, devices, etc.) used where goods and services are offered, across both physical and digital carriers.

1. Article 10.1: the new “non-advertising consumer information” rule

Article 10.1 applies to “information intended for public consumer viewing and not constituting advertising”, with carve-outs for certain mandatory statutory information (Articles 8–10 of the same law).

Three compliance rules matter:

• Russian is mandatory: the information must be in Russian (as the state language).
• Other languages are optional, but only on an “equivalent” basis: identical meaning and equivalent placement/technical presentation.
• Trade marks and company names are carved out: Article 10.1 does not apply to the use of company names, trade marks and service marks, and also does not override other specific legal regimes (technical regulations, EAEU rules, etc.).

As a result, English-only (or “mostly English”) signboards, menus, in-store navigation, POS materials and similar “non-advertising” consumer information become harder to defend unless (i) a Russian version is present and equivalent, or (ii) the foreign element is genuinely used as a protected trade mark/company name.

2. Advertising: the rules stay the same

Advertising remains regulated primarily by the Advertising Law (Law No. 38-FZ). Foreign words in advertising are not prohibited as such, but the overall message must not be misleading or distort meaning; and where an advertising message is duplicated in another language, the Russian version must be equivalent in content and presentation. “Small print Russian” remains high risk.

3. The compliance fork and sanctions: advertising vs consumer information

A single English element can trigger very different exposure depending on classification:

• If treated as advertising: the key risk is CAO RF Article 14.3 (advertising violations). For legal entities, the typical fine range is 100,000–500,000 RUB.
• If treated as non-advertising consumer information under Article 10.1: the baseline risk is CAO RF Article 14.8(1) (violation of the consumer’s right to receive necessary and accurate information). For legal entities, the fine is 5,000–10,000 RUB, and a warning is possible.

Often the bigger cost is remedial action: replacing signage, reprinting menus/POS, rebuilding templates, or scrapping packaging runs.

4. Trade marks as a compliance tool: what they do and do not do

The Article 10.1 carve-out is commercially important: it allows a foreign-language brand identifier to be used without translation where it is used as a trade mark (or company name) element.

How trade marks help

• They give the Latin/foreign element “legal status”, supporting unchanged consumer-facing use of the brand identifier.
• They help scale compliance across networks (retail/franchise), where brand books often contain English elements.

A practical approach is to (i) register the Latin word mark and key stylised variants in Russia for relevant goods/services, and (ii) ensure all surrounding consumer-facing wording (navigation, offers, functional labels, descriptions) is compliant in Russian (and, if bilingual, equivalent).

How trade marks do not help

Trade mark rights will not cure:

• descriptive or promotional foreign wording placed next to the mark (e.g., “sale”, “delivery”, “coffee to go”) — still regulated as advertising or consumer information depending on context;
• mandatory product information regimes (including technical regulations/EAEU rules), which remain Russian-language driven;
• cases where the foreign wording functions descriptively rather than as a source identifier (even if registered), which may still be challenged.

5. Practical checklist (what to do now)

1. Audit: map every consumer-facing text element used in Russia across carriers (storefronts, interiors, packaging, printed materials, websites, apps, templates).
2. Classify each element: (i) trade mark/company name; (ii) advertising; or (iii) Article 10.1 consumer information.
3. For (iii): make Russian primary; if another language is used, ensure equivalence (meaning + placement + technical presentation).
4. For (ii): build “equivalent Russian” into creative templates and agency workflows; avoid relying on fine print translations.

5. For (i): align trade mark filings with real-world use, and keep an “inspection pack” (certificates/licences + approved templates + internal approval rules).

Conclusion

The 2026 amendments make consumer-facing non-advertising wording a clearer compliance target. Trade marks can preserve foreign-language brand identifiers, but they do not legalise foreign-language promotional or informational text around the brand. The safest approach is to protect what must stay foreign (the mark) and Russify (or properly bilingualise) everything else.