We deeply love our homeland. We were born here, grew up here, and have lived most of our lives here. Many people close to us live in Belarus, and we would very much like the whole world to see our country as part of the great human family.
For many years, without losing hope, we tried to integrate Belarus into our small but globally oriented projects and to bring benefit to our homeland — so that the country could receive not only financial gains from exports, but could also take pride in a national premium brand, StasyAlex.
However, due to circumstances beyond our control, the situation became worse every year.
Our cosmetics project, built on our own global e-commerce model — a model that requires accepting payments from all over the world and shipping products to customers worldwide — has been completely paralyzed by the blocking of Belarusian banks and Belarusian logistics.
And so we stand today with a clear understanding of market demand, with 1,000 new premium products already developed — see the catalogue here — with a philosophical novel closely tied to the new products — read the novel here — with educational materials for the new products, with our beloved audience around the world waiting for our new products, and with foreign investors ready to invest in the expansion of our global project, provided relocation is possible.
For many years, we built and positioned our brand as Belarusian, in order to carry beauty, harmony, and love from beautiful Belarus to the whole world.
In 2026, we found ourselves in a situation of nearly complete blocking of Belarusian banks and logistics. We also understood that relocating our cosmetics startup would run into serious banking compliance difficulties simply because of Belarusian residency. Holders of Belarusian passports are often unwillingly denied bank accounts in serious jurisdictions. We categorically do not want to take detours, use loopholes, or resort to deception, because this is humiliating and wrong. We are not criminals or violators. We simply were born where we were born.
Having deferred demand, a developed product line, and foreign investors, we proposed to the Ministry of Economy a legal and fully lawful way to implement the project through the creation of an international holding with Chinese partners and investors. Why did a private initiative need approval from a state body? The reason is simple: in our country, international holding structures are, unfortunately, often viewed with suspicion. The logic of the state is that foreign investment should come directly into Belarus, and production and sales should also take place in Belarus. But, unfortunately, under the current realities and with our product, this is neither legally nor technically possible. Belarus is under sanctions. Foreign investors do not want to enter a country that is under international sanctions and has closed borders. It is also impossible to legally import foreign equipment and raw materials. And sales to more than one hundred countries around the world are impossible for the reasons already described above: banks and logistics are blocked.
One full circle of the relevant state bodies took 73 days — from 30 June to 11 September 2026.
The texts below are English translations. The original documents remain available in Russian through the linked files.
Translation of the proposal to the Ministry of Economy. Russian original: stasyalex.by/docs/mineconomy.pdf
Amid the large-scale transformation of global trade, the Republic of Belarus is forming a new model of long-term economic resilience. The current objectives of the country's economic sector are aimed at creating flexible export-oriented industries capable of generating high added value and securing foreign currency inflows through diversified sales channels. Within the Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030, special attention is given to knowledge-intensive industries and the fine chemical industry, which can effectively replace imported analogues and enter new foreign markets — above all, the markets of Asia, the Middle East, and BRICS.
A serious investor is not interested in empty plots of land or preferential premises as such. The investor needs ready-made projects with confirmed export potential and working international business models capable of building alternative transit and financial routes under conditions of global fragmentation.
Finding such solutions requires a fundamentally different synergy between state resources and private high-tech business. The case of the professional cosmetics brand StasyAlex, created on the basis of LLC "Cosmetic Technologies" in Novopolotsk, clearly demonstrates how domestic developments in colour science and IT technologies — EdTech — can address this fundamental task and return Belarus to the status of a global production hub. In any other jurisdiction, a startup with such fundamentals would become the object of intense competition among venture funds and specialized institutional investors.
Most classical cosmetics projects on the global market require multi-million-dollar investments, of which up to 70% is irreversibly burned in media advertising costs. The Belarusian project followed a fundamentally different and economically efficient path. At the initial stage, with starting working capital of only 60,000 dollars — which was fully returned — the team focused on a deep understanding of market demand, innovation, and impeccable product quality, and built a working international e-commerce system.
The main indicator of the model's viability was the first year of operations. It was during the first twelve months of active work on the global market that the brand made a powerful leap, generating explosive sales and producing the main volume of its foreign currency revenue. This allowed the project not only to repay the initial investment almost immediately, but also to begin stable dividend payments to the co-founders shortly afterwards.
The uniqueness of this result lies in the complete reliance on the organic trust of the professional community. Sales were launched without marketing budgets — after a quiet announcement on Instagram. Explosive, avalanche-like demand formed naturally: receiving products marked "Made in Belarus", professional makeup artists and retail customers massively shared sincere emotions, filmed video reviews, and incorporated the cosmetics into their daily work. Each loyal customer brought dozens of new consumers.
The product received an exceptionally warm response from the beauty community worldwide. Even under geopolitical pressure, no claim arose from international regulatory bodies regarding the quality, formulation, or safety of Belarusian cosmetics. However, restrictions on the import of European chemical raw materials and equipment, sanctions against Belarusian banks, and closed borders require the business to be scaled — a business that already has growing deferred demand — and transferred onto the rails of interstate cooperation.
The main reason this project is of exceptional interest to international capital is the presence of a powerful scientific and methodological foundation created in Belarus. Unlike standard cosmetics production, the StasyAlex brand sells not merely a physical product, but a complete intellectual ecosystem.
The foundation of this ecosystem is the scientific and practical work "Metamorphoses of Colour". This is a full academic study in the physics of colour, light, anatomical logic, and natural colour harmony. The book has been translated into the key languages of the world and serves as a basic textbook for an international online makeup school — EdTech. The project trains specialists for the global market according to its own logically grounded and practically applicable standards of colour science.
The direct material embodiment of this scientific theory is the new collection recorded in the official AMORAVES catalogue. This is not merely a product line, but a unique conceptual ecosystem of professional cosmetics built on the laws of natural colour harmony. The design and palettes of the complex multi-colour AVIAN palettes fully reproduce the ideal colour harmonies of living nature and birds. Every product in the AMORAVES catalogue has high collectible value for the professional community. The synergy of the book, online education, and a finished physical product creates a unique algorithm: international specialists are trained through Belarusian books and methods, which automatically generates conscious, long-term, and avalanche-like demand for the specific cosmetics presented in the catalogue.
The presence of such a closed, self-reproducing sales system is the main argument for investing capital.
The officially announced Years of Industrial Cooperation between Belarus and China open the possibility for the government's economic sector to implement a flagship pilot project involving 5 million dollars of foreign direct investment. The new model solves the main task: it gives a large Chinese investor a legal and protected route to premium markets with maximum added value — the countries of the Middle East, such as the UAE, Saudi Arabia, and Qatar, China, the BRICS and SCO countries, and also — because cosmetics are absent from all sanctions packages — the EU and US markets.
In effect, Belarus returns to its original concept of "Great Stone" as a jurisdictional bridge for Asian capital into global markets, but in a new hybrid format — not through sanctioned goods, but through high-margin products that do not fall under restrictive regimes.
The logic of the project is built on a clear separation of production stages.
A specialized strategic investor from China — Guangdong province — enters the joint venture with its technological capacities. At the partner factory in China, using local high-purity raw materials and under the guidance of the Belarusian team, unique branded packaging is produced for the AMORAVES collection, and base cosmetic masses are synthesized according to the technological documents and formulations. The semi-finished products are initially provided with international safety passports — MSDS — of the Chinese standard, which fully removes compliance risks during further certification.
Then the raw semi-finished product arrives at a new resident enterprise of the "Great Stone" Industrial Park at a zero duty and VAT rate. Within the allocated budget, inside a rented standard module, a ready-to-assemble engineering structure of clean rooms — HPL panels and supply ventilation with HEPA filters — is installed within three weeks to meet the international cosmetic GMP standard. Within this contour, under the author's supervision of the domestic developers, the key stage takes place: the introduction of exclusive pigments, final blending of complex textures, laboratory control, and filling. The product enters the market under the official and reputationally strong marking "StasyAlex Made in Belarus", preserving its historical identity.
Finished products are shipped in large batches from Belarus to regional warehouses of decentralized fulfilment in Poland, the United States, and the UAE. Dubai serves not merely as a warehouse, but as a key geopolitical hub for the markets of the Gulf Cooperation Council — a vector that corresponds to the official export diversification priorities set out in Resolution of the Council of Ministers No. 813.
The proposed architecture protects operational activities from cross-border banking blockages and simultaneously guarantees full fulfilment of the currency plans of the Ministry of Economy and the National Bank of the Republic of Belarus.
At the stage of customs clearance in the EU and the United States, the seller is the parent international holding — Hong Kong or Dubai — while the country of origin remains Belarus. Retail customers purchase the product through local websites, and funds are accumulated via Stripe or PayPal gateways in the holding's foreign accounts.
It is important to understand the nature of this structure: the presence of a parent holding in the UAE or Hong Kong is not an instrument of tax optimization, but the only possible compliance shield for the Chinese investor. The Chinese manufacturing partner physically cannot enter the Belarusian jurisdiction and sell directly through Stripe or PayPal to the United States and the EU without the risk of secondary sanctions. The holding acts as a sanctions buffer that allows Asian capital to trade safely with premium Western and Middle Eastern consumers without risking its mainland assets.
The holding officially transfers currency — in yuan or dollars — to the Belarusian resident in "Great Stone" as payment for contract assembly services — tolling — and to the base company as licensing royalties for the EdTech platform and books. For the controlling bodies of the Republic, this is a clean and transparent export of high-tech production and intellectual services, fully satisfying the requirements of Decree No. 178 and the priorities of the 2026–2030 Programme regarding digital transformation and IT services exports.
Thus, the project creates a protected monetization channel in markets with maximum margins, using the Belarusian jurisdiction as a security guarantor for the Asian investor. For the National Bank and the Ministry of Economy, this means an inflow of hard currency into the country — outwardly presented through the Eastern vector, namely the Chinese joint venture and the UAE hub, but actually extracted from premium Western and Middle Eastern markets.
The project's performance indicators are confirmed by a precise calculation of the first industrial batch from the updated AMORAVES collection, amounting to 405,500 units.
If the same volume were produced at the former base in Novopolotsk, total costs under sanctions conditions would amount to approximately 2,200,000 dollars, assuming access to investment and technological equipment — an access that is absent because of sanctions. The new hybrid model significantly optimizes component procurement costs in China. The profitability potential calculation is based on minimum wholesale prices, which include the maximum discount for promotions and distribution: the average wholesale price per unit is 19.44 dollars; the total base revenue of the holding reaches 7,882,500 dollars; and the total cost of the batch within the PRC–Belarus contour is 2,142,278 dollars. After deducting estimated acquiring costs and taxes, the net profit from one cycle is 4,871,038 dollars.
When the new marketing strategy is included — targeted EdTech seeding, under which 2% of the produced volume will be sent free of charge to the international network of online school graduates, including opinion leaders with their own salons from Warsaw to Dubai — the full sale of the starting batch is expected to take only 6–12 months. Moving to direct retail e-commerce prices — which are on average 40% higher than the calculated wholesale prices — would increase the debut batch revenue to 11 million dollars, ensuring payback of the investor's full 5 million dollars already in the first year.
At the same time, the existing LLC "Cosmetic Technologies" in Novopolotsk bears no infrastructure costs: it is freed from production load, purchases the finished wholesale volume from "Great Stone", and systematically scales sales in the EAEU market — Belarus, Russia, and Kazakhstan.
The project to scale the StasyAlex brand is a ready-made and economically justified instrument for qualitatively changing the investment agenda of the Ministry of Economy and the National Agency for Investment and Privatization. Instead of trying to attract investors "to nowhere", the agencies receive a packaged project that solves the main task of Asian capital — access to premium global markets through a safe jurisdiction.
The state is not required to allocate budget subsidies or attract loans. The project is fully financed by private capital from China. The role of the National Agency for Investment and Privatization and the Ministry of Foreign Affairs here is a partnership role — to consider the possibility of including the StasyAlex investment passport in the pool of priority PRC–Belarus industrial cooperation cases and of using this project, including in closed mode, by the diplomatic and trade missions of Belarus in Beijing, Shanghai, and Guangzhou as proof that the Belarusian platform remains a working instrument for Asian business even under current conditions.
For the ministries, this is a model case of attracting foreign direct investment that is protected from external risks and demonstrates:
P.S. No sanctions package contains cosmetics. This project could become the first to produce innovative premium products with high added value for the global market and to be officially and legally supplied to the European Union and the United States with the proud marking "Made in Belarus". The possibilities for global market scaling are unlimited.
The volume of more than 400,000 units is caused by the first 135 SKUs from the more than 1,000 developed, and only because we are starting small, not being certain that we can attract investment under Belarusian conditions. Without state participation — no matter how excellent an export project may be created and tested as an MVP — it will run into the exceptional regulatory framework of the EAEU and the unwillingness of investors to deal with Belarusian residents. Attracting 5 million dollars of investment for a Belarusian startup is already an achievement.
Please consider the possibility of implementing this project in accordance with the existing regulatory framework of the Republic of Belarus and the EAEU, and in the context of the Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030, especially Chapter 2.
Programme of Socio-Economic Development for 2026–2030
If necessary, I am ready to provide all additional documents: the draft business plan, the project structure, and all necessary explanations.
Translation of the response of the Ministry of Economy. Russian original: stasyalex.by/docs/21317799.pdf
Dear Aleksey Aleksandrovich,
The Ministry of Economy of the Republic of Belarus, together with the State Institution "National Agency for Investment and Privatization" — NAIP — has reviewed your electronic appeal dated 7 July 2026 within its competence and reports the following.
In order to officially present the investment project mentioned in your appeal, we recommend using the interactive portal "Investment Portal of the Republic of Belarus" — map.investinbelarus.by — created by NAIP. The portal contains, among other things, a register of investor appeals containing proposals for investment cooperation, including those submitted through the form on the NAIP website.
Placement of the project on this portal is carried out free of charge.
NAIP is also ready to provide consultative support on the preparation of investment materials and the presentation of the project. To receive such consultations, you may contact map@investinbelarus.by or phone +375 17 200 22 19.
After moderation, the project may be included in NAIP's thematic collections of investment proposals for distribution through diplomatic channels, which will attract the attention of potential foreign investors or partners, including those from China.
Also, if foreign partners show interest in the project, it may be possible to hold business meetings at NAIP to discuss plans and ideas for the implementation of your project.
In addition, the Ministry of Economy, together with NAIP, has developed a visual Guide to State Support Measures for Business in the Republic of Belarus. It contains information about the preferential regimes in force in the Republic of Belarus, including the "Great Stone" Industrial Park, existing business support measures, and possible forms of state financial support. The Guide is published on the website of the Ministry of Economy at economy.gov.by/ru/gidinvest-ru/.
Note: The Guide link provided in the Ministry's response — economy.gov.by/ru/gidinvest-ru/ — appears to be unavailable or incorrect. Please verify the current address on the official website of the Ministry of Economy.
Our proposal of 7 July concerned a specific, fully prepared structure: a hybrid PRC–Belarus joint venture with a Chinese investor who had already been identified and had confirmed readiness to invest 5 million dollars; a working export business whose first-year revenue had already been received; and one concrete request — an official examination of the lawfulness of the proposed holding model. The proposal explicitly relied on the economic tasks set by the Head of State. Speaking on the development of exports to China, President Lukashenko stated:
«I am confident that we can do more. The levers are known: our own distribution network with warehouses and logistics. Direct supplies, including to retail chains and to the end consumer through e-commerce. Joint productions on their territory and here — specifically for the Chinese buyer. Finally, work with the Chinese regions, which is frankly lagging,» the Belarusian leader said.
Source: official news agency BelTA
Instead of an examination of the proposed structure, the reply recommends placing the project on the national investment portal — a register designed for projects at the stage of searching for an investor. Our project was not searching for one: the investor, the financing and the working export model already existed. What the project required was not a board for finding investors, but a substantive legal assessment of the hybrid model — precisely what had been requested. For a business that already has an investor and export revenue, placement on such a portal could not advance the matter.
The result: the only path formally proposed to a project that already had an investor and a working export model was the path of a project that has neither.
The second direction of our work is functional food products and health: food.stasyalex.com.
As with cosmetics, the theme of developing functional food products did not arise from nothing. It became a response to our own needs and the needs of our friends around the world. Continuous deep analysis, study of the latest discoveries, and review of global research allowed us to develop several lines of functional food products, most of which were based on Belarusian raw materials. Belarus has a large and excellent food raw material base, and we sincerely wanted to use this opportunity to establish the development and production of food products in demand around the world.
View our catalogue of functional food products
To implement this plan, we already had foreign investors, and negotiations had been held with the National Agency for Investment and Privatization. We received moral support and approval from the state through NAIP. The first stage was planned to be the refinement and prototyping of several products on existing laboratory bases and pilot production facilities in Belarus.
After a detailed search across the whole country, it turned out that pilot production exists only at the Scientific and Practical Centre of the National Academy of Sciences of Belarus for Food in Maryina Gorka. However, attempting to rent this facility for the refinement and prototyping of our developments proved impossible.
As the management of the Scientific and Practical Centre for Food explained: they do not provide such services; moreover, all developments for external markets — the EU, the United States, and the Middle East — are prohibited in Belarus. Development and production are possible only for the internal regulations and regulatory framework of the EAEU. We were also given to understand that the planned construction, together with investors, of our own R&D centre for developing food products according to global standards would also be blocked.
Here is what we wanted to build in Belarus:
R&D Centre concept | R&D Annex 1 | R&D Annex 2
Understanding that Belarus nevertheless needs innovative products, high-margin export products made from our Belarusian raw materials, and foreign investment — as described in the State Programme of Socio-Economic Development for 2026–2030 — we sent a proposal to the Administration of the President to consider creating a state innovation R&D centre, since private developers and foreign investors are not allowed to do so.
From the Administration of the President, our proposal was forwarded to the apparatus of the Council of Ministers of the Republic of Belarus, and from there it returned to the National Academy of Sciences — exactly to the place where we had already received a refusal during an in-person meeting.
Translation of the proposal sent to the Administration of the President. Russian original: stasyalex.by/docs/AP-Food03072600000117.pdf
A group of initiative-driven developers from Belarus has developed nine categories of innovative food products, primarily functional products, for the needs of the premium markets of the EU, the United States, the Middle East, and Asia. The full list is available at food.stasyalex.com/blog.
To realize the export potential, all development is carried out according to the regulatory base and requirements of EFSA, FDA, and other regulators, excluding the EAEU. Interest in the developments has been shown by both Western companies and investors, as well as Chinese companies. For more than one year, there have been proposals to relocate the project from the EAEU to another jurisdiction. We are still holding on and trying to find ways to develop Belarus's export potential, doing our best to persuade investors not to write Belarus off.
Investors have proposed refining and prototyping our developments in Belarusian laboratories on a paid basis for further scaling at Western enterprises and studying markets through MVPs. Since Belarus has no private R&D centres, we applied to the State Committee on Science and Technology and to the Scientific and Practical Centre of the National Academy of Sciences of Belarus for Food with a request to provide, on a paid basis, the services of the NPC pilot production facility in Maryina Gorka. Unfortunately, neither laboratory research nor pilot production services could be obtained.
The Scientific and Practical Centre for Food explained that it does not provide such services, works exclusively "for the production line", and operates exclusively within the regulatory framework of the EAEU — that is, for the internal market.
To the question whether we could build a separate R&D laboratory and pilot production facility in Belarus using foreign investors' funds, oriented toward developing high-margin advanced food products according to global standards, the Scientific and Practical Centre for Food explained that no one in Belarus would allow this. It does not matter that you want to develop and produce products only for export; you will still be obliged to work exclusively according to EAEU regulations and norms, and only according to them. Therefore, even the option of an innovation sandbox initiated by private actors is categorically impossible.
We accept the situation with understanding, although it is difficult. There are established rules — the EAEU — and no official will take responsibility for proposing an exception, however noble the goal may be: innovation and export.
Meanwhile, for many years we have been working to ensure that Belarus participates in exports to the global market, creates innovative and advanced products, and becomes recognizable and respected. Previously, we were already forced to hand over the results of our previous export cosmetics startup to Chinese companies: innovative developments, technologies, and the market. The story is available at stasyalex.com/history.
But that was cosmetics. Now we are talking about food, about functional food products in Belarus, where there is a huge and excellent raw material base and enormous potential for exporting high-margin products with high added value. Perhaps, at the present moment, any initiative to study international standards deeply and gradually harmonize with them may seem meaningless: sanctions, protective duties, logistics. But strategically, if one looks at the map and at the efforts undertaken by the President to normalize relations with neighbours, it becomes clear that isolation will not last forever and that one must prepare for this already now, independently seeking ways to enter external markets.
The Head of State has for many years demanded that the government diversify markets, master and produce high-margin products, and increase exports. The main risks for the country are well described in the Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030, particularly in Chapter 2, and have been repeatedly voiced by the President. However, self-isolation within the EAEU regulatory framework does nothing to overcome the problems stated in Chapter 2 of the Programme and does not contribute to fulfilling the President's requirements.
Unfortunately, Belarus does not have a single innovative food R&D centre. Around the world this is absolutely normal practice: food corporations collect and test interesting ideas and innovations. Nestlé and Danone follow this practice, aggregating the initiatives of small startups and private developers through their own R&D networks, studying and shaping global trends. PepsiCo Labs and Coca-Cola are engaged in similar activities, as are hundreds of advanced private R&D centres. Examples include Mattson in the United States, NIZO in the Netherlands, and Food Research Lab in India.
There are many such centres in China. Work on functional food and beverage innovation has also been underway for many years in Russia. Without breakthrough innovations, Belarus already finds it difficult to compete with food producers from China and Russia, even in the internal Belarusian market.
I propose considering the creation of a state research R&D centre for food, whose activities would be placed outside the EAEU regulatory framework. A pilot project. Such an R&D model would allow the development of high-margin food products based on Belarusian raw materials for specific external markets. Such a project could be interesting to serious Chinese investors, because it has global export potential and could, in the future, help solve the tasks of market diversification, export growth, and increased added value.
As an example of what we planned to implement together with foreign investors, we present the FITWIT R&D project. We understand that a private initiative cannot initiate a refusal to comply with regulator requirements to live according to EAEU regulations. But the creation of a similar R&D laboratory by the state itself, with the right to work according to international standards, would make it possible to return such advanced private investment, keep our talent inside the country, and create a legal, high-margin export gateway for transferring technologies and, in the future, food products to premium markets around the world — and to begin work on harmonizing and synchronizing our food industry with global markets.
Attachments for review:
Translation of the response of the National Academy of Sciences. Russian original: stasyalex.by/docs/nan-food.pdf
Dear Aleksey Aleksandrovich,
The National Academy of Sciences of Belarus informs you that your appeal to the Administration of the President of the Republic of Belarus concerning the creation of a pilot R&D centre of advanced development has been considered by the Republican Unitary Enterprise "Scientific and Practical Centre of the National Academy of Sciences of Belarus for Food", and the following is reported.
In accordance with the international obligations of the Republic of Belarus within the Eurasian Economic Union, the development, production, and circulation of food products in the territory of the Republic are strictly regulated by the requirements of the Technical Regulations of the Customs Union, in particular TR CU 021/2011 "On Food Safety". First of all, this is aimed at protecting human life and health, as well as preventing consumers from being misled. The creation of separate regulatory production facilities completely excluded from the unified EAEU regulatory framework is not provided for by current legislation.
The activities of the Scientific and Practical Centre for Food are oriented toward ensuring food security and import substitution within the framework of the legislation and technical normative legal acts in force in the country. The Scientific and Practical Centre for Food is, by its essence, the key state R&D centre in the food industry. Its activities are entirely aimed at developing and creating innovative technologies and product formulations, including products of functional purpose.
All developments are carried out through close scientific and technological cooperation with leading food manufacturing enterprises of the Republic, ensuring the transfer of innovations from the laboratory stage to the real sector of the economy, taking into account consumer demand and enterprise capabilities.
When forming the normative and technical base, the specialists of the Scientific and Practical Centre for Food rely not only on the normative documents of the Republic of Belarus and the Russian Federation, but also on international-level standards. The development of the overwhelming majority of technical normative legal acts for food products is carried out on the basis of international requirements, including Codex Alimentarius standards, ISO recommendations, and others. This approach is implemented systematically precisely to expand markets, remove technical barriers, and increase the competitiveness of domestic producers' products in the global market.
The staff of the Scientific and Practical Centre for Food are interested in expanding scientific and technological cooperation and diversifying exports of Belarusian products to third-country markets and are ready to consider the possibility of conducting laboratory research and testing of the innovative formulations proposed in your appeal on a contractual basis, provided the technological parameters of the declared products do not fundamentally contradict the safety requirements in force in the Republic of Belarus.
For a detailed and substantive discussion of the conceptual materials presented and to find possible ways of cooperation within the legal field, we invite you, dear Aleksey Aleksandrovich, and representatives of the initiative group again to a working meeting at the Scientific and Practical Centre for Food.
First Deputy Chairman of the Presidium of the National Academy of Sciences of Belarus, V. G. Zalessky
In its response, the National Academy of Sciences once again confirms that there can be no innovations or export exceptions in Belarus: the entire regulatory framework is created exclusively for the internal EAEU market.
We then attempted to find support for the implementation of export-oriented projects important for the country through the Ministry of Foreign Affairs. The Ministry of Foreign Affairs of the Republic of Belarus is directly involved in foreign economic activity.
Translation of the appeal to the Ministry of Foreign Affairs. Russian original: stasyalex.by/docs/in_mid.pdf
My appeal No. 03072600000117 dated 30 June 2026 to the Administration of the President, forwarded to the apparatus of the Council of Ministers and then to the National Academy of Sciences, contained a proposal on creating an R&D centre of advanced development for export diversification, harmonization with global standards, and creation of high-value-added food industry products. A response was received, and it causes some bewilderment.
I ask the Ministry of Foreign Affairs to carefully analyze both the appeal and the response to it, because this directly concerns the functions of the Ministry of Foreign Affairs and coordination of foreign economic activity.
In my appeal No. 03072600000117 dated 30 June 2026, I deliberately take the EAEU market out of the equation and focus attention on exports, external markets, including the markets of the "far arc". I pay special attention to Chapter 2 of the Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030 and to the Head of State's requirements concerning market diversification, innovation, added value, and foreign direct investment.
The response of the National Academy of Sciences states: "In accordance with the international obligations of the Republic of Belarus within the Eurasian Economic Union, the development, production, and circulation of food products in the territory of the Republic are strictly regulated by the requirements of the Technical Regulations of the Customs Union, in particular TR CU 021/2011 'On Food Safety'," and "The creation of separate regulatory production facilities completely excluded from the unified EAEU regulatory framework is not provided for by current legislation."
The response of the National Academy of Sciences produces a depressing picture: while the President is making maximum efforts to diversify exports, develop efficient high-value-added production, and attract foreign direct investment into the country, technically, through the regulatory framework, the country's economy turns out to be locked inside the EAEU. The regulations and certification model are recognized nowhere except the EAEU itself, and export supplies outside the EAEU will remain exclusively raw-material-based.
Because there is no harmonization or synchronization of certification models with external markets, and not even an operational understanding of rapidly changing global regulatory requirements, supplies of non-resource food products to external markets will be symbolic and will impose large certification and approval costs on producers.
Relying on the Regulation on the Ministry of Foreign Affairs and the supervisory functions of the Ministry of Foreign Affairs — paragraphs 7 and 11 of Resolution of the Council of Ministers No. 813 — we ask you, as experienced diplomats and strategists of foreign economic activity, to help clarify the following questions:
P.S. I attach the text of the appeal to the Administration of the President and the response of the National Academy of Sciences. Please take the attachment files from the appeals system. If necessary, I can provide the attachment files separately and give any necessary explanations.
I consider it unacceptable to lose foreign investors and to push innovative export-oriented projects out of Belarus.
Translation of the response of the Ministry of Foreign Affairs. Russian original: stasyalex.by/docs/mid.pdf
The Ministry of Foreign Affairs has reviewed your appeal No. 03072600000141 within its competence and reports the following on the substance of the questions raised.
The Republic of Belarus is a full member of international standardization organizations such as the International Organization for Standardization — ISO — and the International Electrotechnical Commission — IEC. Participation in their work promotes the adoption and implementation of advanced experience and technologies in the relevant fields, the removal of technical barriers in trade, the strengthening of the country's image and trust in Belarusian products, and the promotion of the country's interests in international arenas.
In accordance with the annual state standardization plans, the Republic of Belarus develops and implements state and international standards harmonized with international and European standards, and creates the relevant national laboratories and centres.
In accordance with Article 6 of the Law of the Republic of Belarus dated 5 January 2004 No. 262-Z "On Technical Regulation and Standardization", the body exercising state regulation in the field of technical regulation and standardization is the State Committee for Standardization of the Republic of Belarus — Gosstandart.
By Resolution of the Council of Ministers of the Republic of Belarus dated 23 March 2023 No. 200, Gosstandart, together with the Ministry of Agriculture and Food and the Ministry of Health, is also designated as the regulating body of the Republic of Belarus in the sphere of technical regulation, veterinary and sanitary measures, and quarantine phytosanitary measures of the Eurasian Economic Commission.
In this regard, on the issue of applying the norms of the Eurasian Economic Union Treaty in the field of technical regulation, as well as national legislation on technical regulation and standardization, we believe it appropriate to contact Gosstandart.
Information on certification of food products for export to the markets of the EU, the United States, and China by EAEU member states is available only to the competent bodies of those states.
The Ministry of Foreign Affairs, together with interested state bodies and organizations of the Republic of Belarus, is conducting systematic work to expand access of Belarusian products to the markets of the CIS, Asia, the Middle East, Africa, and Latin America — including accreditation of Belarusian producers, accreditation and certification of products, and ensuring compliance with Halal standards.
Deputy Minister of Foreign Affairs, P. V. Utyupin
In its response, the Ministry of Foreign Affairs unfortunately provides no substantive explanations. The response also indicates that the Ministry of Foreign Affairs of Belarus does not know how partner countries of the EAEU carry out export activity and suggests asking them directly. The Ministry also advises us to contact the State Committee for Standardization of the Republic of Belarus.
Following the advice of the Ministry of Foreign Affairs, we contacted the State Committee for Standardization of the Republic of Belarus, without entertaining any illusions. In Belarus, unfortunately, there is no single body responsible for implementing the investment, innovation, and export objectives of the State Programme of Socio-Economic Development for 2026–2030. Correspondence with state bodies and ministries is extremely slow, and the responses are formal. Time is passing, and foreign investors, unfortunately, are not prepared for formalism and long waits for answers to simple questions.
Translation of the appeal to the State Committee for Standardization. Russian original: stasyalex.by/docs/in_gosstandart.pdf
To the State Committee for Standardization of the Republic of Belarus
Date of submission: 28 August 2026
I ask the State Committee for Standardization of the Republic of Belarus, within its competence, to provide detailed clarifications on how the development and production of food products intended exclusively for export outside the Eurasian Economic Union, without their release into civil circulation within the Union, are regulated legally and in practice.
When preparing the response, I ask you to take into account the context of my previous appeals:
An analysis of these responses, taken together with the objectives set in Chapter 2 of the State Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030 concerning market diversification, attraction of foreign direct investment, and increased non-resource exports, reveals systemic regulatory limitations. There is a justified concern that the current model of technical regulation de facto restricts innovation and production activity to the EAEU internal market, which directly correlates with the low indicators of non-resource exports and foreign direct investment noted in the Programme.
In addition, asymmetric conditions for producers are observed within the EAEU internal market. For example, the use of certain innovative ingredients — such as monk fruit extract — is permitted in products manufactured in Russia and supplied to Belarus, while Belarusian developers are denied similar opportunities even when the product is created exclusively for export to third countries, such as the United States or the EU, where these ingredients are approved by regulators.
The "Programme of Strategic Development of Technical Regulation of the Republic of Belarus until 2030" declares goals of increasing competitiveness and harmonizing standards. However, in practice, as follows from the responses of the National Academy of Sciences and the Ministry of Foreign Affairs, export-oriented R&D projects encounter insurmountable administrative barriers and a lack of understanding of how other EAEU members export.
In connection with the above, I ask for concrete answers to the following questions:
Attachments:
The response of the State Committee for Standardization is published below.
Translation of the response of the State Committee for Standardization. Russian original: stasyalex.by/docs/gosstandart.pdf
On the consideration of your appeal
The State Committee for Standardization of the Republic of Belarus (hereinafter — Gosstandart) has considered your appeal concerning the regulation of the development and production of food products intended exclusively for export beyond the Eurasian Economic Union and reports the following within its competence.
1. In accordance with paragraph 5 of Article 19 of the Law of the Republic of Belarus of 5 January 2004 No. 262-Z "On Technical Regulation and Standardization" (hereinafter — Law No. 262), when products are manufactured in the Republic of Belarus for sale for export beyond the customs territory of the Eurasian Economic Union (hereinafter, unless otherwise defined — EAEU), if the terms of a foreign trade contract establish technical requirements other than those set by the technical regulations of the Republic of Belarus (hereinafter — TR RB) or the technical regulations of the Eurasian Economic Union (hereinafter — TR EAEU), the conditions of such contract shall apply. By virtue of Article 33 of Law No. 262, this rule also extends to the technical regulations of the Customs Union (hereinafter — TR CU).
At the same time, it should be taken into account that the rule of paragraph 5 of Article 19 of Law No. 262 does not extend to other (other than TR RB) types of normative legal acts of the Republic of Belarus, including mandatory technical normative legal acts, nor to other (other than TR EAEU, TR CU) acts (documents) within the law of the EAEU. A necessary condition for the application of this rule is the existence of a concluded foreign trade contract that defines, either directly or by reference, the applicable technical requirements.
We additionally inform you that the state standard STB 993-95 "Supply of goods for export. Basic provisions" is in force in the Republic of Belarus. The standard establishes the basic provisions for the organization of the supply of goods for export and the procedure for the execution of shipping documentation. The standard applies to all types of products, with the exception of non-food alcohol-containing products.
Current national legislation and the law of the EAEU do not differentiate mandatory requirements for production processes and product safety depending on the geographical direction of the product's subsequent sale. The legislation contains no provisions on exemptions, special regulatory regimes, or complete release from compliance with the union technical regulations for products manufactured exclusively for export. At the same time, the manufacturer has the right additionally to apply the standards and requirements of the countries of destination (FDA, EFSA, etc.) in order to secure access to external markets.
Thus, when manufacturing products in the Republic of Belarus for export beyond the EAEU, the manufacturer is obliged to comply strictly with the technical requirements of the country to which the product is supplied.
2. Synchronization with global requirements is ensured through the implementation of state standardization plans providing for the planned alignment of national (STB) and interstate (GOST) standards with international analogues (ISO, IEC, the Codex Alimentarius Commission). The step-by-step achievement of an 85% harmonization level by 2030 is conditioned by the need for the gradual adaptation of domestic industry and the testing base to international criteria, without creating a critical regulatory and financial burden on enterprises. Scientific research organizations, including state ones, are obliged in their activities to proceed from the principle of the legality of the subsequent implementation of developments in the real sector of the economy, which requires strict compliance with the normative legal acts in force on the territory of the republic.
3. In the food industry, "harmonization" means the technical, substantive, and methodological convergence of the safety indicators, test methods, and identification characteristics of national standards with international analogues (first and foremost, with the standards of the Codex Alimentarius Commission). The mechanism for taking into account the dynamics of external markets is implemented through the participation of technical committees for standardization in international activities. However, the use of innovative ingredients (including the monk fruit extract mentioned) in industrial production on the territory of the Republic of Belarus is directly limited by the provisions of the union regulation TR CU 029/2012. The use of components not included in the lists permitted by national legislation is not allowed, regardless of the intended further use of the product.
4. Matters of certification and accreditation for the purpose of conferring the "Halal" status on products do not fall within either the legislation of the Republic of Belarus on conformity assessment to technical requirements or the legislation in the sphere of accreditation within the National Accreditation System of the Republic of Belarus. Accordingly, Gosstandart, as the regulating body in the indicated areas of the legislation of the Republic of Belarus, is not competent to provide comments on this issue.
5. The creation of separate regulatory "sandboxes" or a unilateral separation of union and export regulation fall outside the exclusive competence of Gosstandart.
For reference:
In accordance with subparagraph 4.1 of paragraph 4 of the Regulations approved by Resolution of the Council of Ministers of the Republic of Belarus of 31 July 2006 No. 981, the main tasks of Gosstandart are the conduct of a unified state policy in the field of technical regulation, standardization, ensuring unity of measurements, conformity assessment and accreditation, energy saving, and the use of renewable energy sources.
At the same time, Gosstandart, within the limits of its powers, is ready to consider and work out initiatives aimed at the improvement of technical regulation and standardization.
This response may be appealed in accordance with Article 20 of the Law of the Republic of Belarus of 18 July 2011 No. 300-Z "On Appeals of Citizens and Legal Entities" to a court in the procedure established by law.
First Deputy Chairman of the State Committee for Standardization, A. A. Burak
Official correspondence in Belarus is written in a regulatory dialect that can be difficult for a foreign reader. Below, we translate the answer of the country's principal technical regulator into plain language:
The core contradiction. Chapter 2 of the State Programme of Socio-Economic Development for 2026–2030 officially records the country's key risks — raw-material exports, a low share of high-tech products, insufficient foreign investment — and the Head of State has for many years publicly demanded high-margin production, innovation, and export growth. The response of Gosstandart confirms in writing that the regulatory framework de facto locks all development and production inside the EAEU; that ingredients approved by regulators worldwide cannot be used even in products manufactured exclusively for export; and that no institution exists whose task it would be to reconcile the declared policy with the legal reality. The strategic goals of the state and its regulatory practice contradict each other. This contradiction is structural rather than personal: it is not the result of the bad will of any official, but of the absence of any state body that regards the implementation of Chapter 2 of the Programme as its own task.
We publish this correspondence not to complain about our country. We publish it to show — with documents in hand — that we did everything that was in our power, and even more.
It is obvious that we did everything in our power to try, at least partially, to address the acute issues and challenges set out in the State Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030.
Original document: Programme of Socio-Economic Development of the Republic of Belarus for 2026–2030
The key risks for Belarus are low country diversification of exports and an insufficiently differentiated export commodity structure with a predominance of raw-material goods. The share of high-tech goods in exports remains low — 5.4 percent, while in China it is 25 percent. The share of investment goods has practically not changed and remains at the level of 10–12 percent; in 2024 it was 12.2 percent. At the same time, the share of other intermediate goods — raw materials, materials, and components — is high, at more than 50 percent.
It is necessary to strengthen the turn of national exports to the markets of Asia, the Middle East, Africa, and Latin America, to increase supply volumes to the markets of the Commonwealth of Independent States, and to raise the share of high-technology, medium-high-technology, and knowledge-intensive products in the export structure.
The Republic of Belarus retains a number of systemic imbalances: a low technological structure; a chronically low level of implementation of research and development results and patents; a weak mechanism of interaction between science, production, and education; a shortage of scientific personnel; insufficient use of the private sector's potential; low investment activity; and limited long-term investment resources in the financial sector.
It is necessary to raise investment activity, create industrial parks with ready infrastructure, and stimulate the inflow of foreign direct investment into the economy.
Indicators: internal expenditure on research and development as a share of GDP should reach at least 1 percent by 2030, compared to 0.59 percent in 2024; the share of innovation-active organizations among surveyed manufacturing organizations should reach at least 45% by 2030, compared to 40% in 2024.
The Programme provides for the development of scientific support in priority areas, increasing the effectiveness of commercialization of intellectual property, strengthening the integration of academic, university, and sectoral science, expanding interaction between economic entities and scientific organizations, improving financing of scientific, scientific-technical, and innovative activity, forming an institutional environment that stimulates innovation, and developing institutions for supporting scientific and technical activity — technology parks, technology transfer centres, business incubators, engineering companies, and technological platforms.
Indicators: growth of exports of goods and services should be at least 1.2 times over the five-year period; diversification of foreign trade through an increased share of the "far arc" countries should reach 30 percent by 2030, compared to 19.1 percent in 2024; the share of high-technology, medium-high-technology, and knowledge-intensive products in exports of goods and services should reach at least 44 percent by 2030, compared to 38.1 percent in 2024.
The Programme provides for increasing food and agricultural raw material exports to 10–12 billion US dollars by 2030, expanding geography, developing trade and economic relations with South-East Asia, the Middle East, Africa, and Latin America, stimulating shipments to "far arc" countries, and improving export support mechanisms.
Dairy Valley is not a commercial project of our company. It is a strategic concept developed by our team on a pro bono basis — as a direct, practical response to the challenges documented in Chapter 2 of the State Programme of Socio-Economic Development for 2026–2030: the predominance of raw materials in the export structure, the low share of high-value-added products, and the urgent need for market diversification.
The concept describes an investment platform for deep milk processing with a capacity of 500–1,000 tons per day, oriented toward the export of high-value-added ingredients — to China, the EAEU, MENA, and ASEAN. The full strategic and financial architecture has been completed: market analysis, technology selection, CAPEX structure, scenario modelling, and investment metrics (IRR, NPV, payback). The concept is integrated with the Strategy for the Development of the Dairy Industry of the Republic of Belarus for 2026–2035 and the State Programme of Socio-Economic Development.
We deliberately make this concept publicly available as an open document. Any state body, domestic producer, or foreign partner is free to study, use, and implement it. The preparation of national-scale concepts — beyond one's own commercial interests — is, in our view, the natural way of thinking for a team that works with strategy, not only with projects.
At the same time, we harbour no illusions about the feasibility of implementing such a concept in Belarus under the institutional conditions illustrated by the correspondence published on this page. We therefore document the concept here in full: both as our contribution to the strategic discussion about the future of the country's dairy industry — and as a ready-made, thoroughly calculated foundation for partners in any jurisdiction where the conditions allow its realization. Should any foreign state, sovereign fund, or industrial investor be interested in implementing this concept — in whole or in part — we remain open to substantive cooperation and to transferring our expertise.
Complete strategic justification, market analysis, technology details, and implementation roadmap for the Dairy Valley concept.
Detailed financial model, CAPEX structure, scenario analysis, risk assessment, and investment metrics (IRR, NPV, payback period).
For foreign partners unfamiliar with the realities of Belarus, it may seem incredible that export-oriented, highly profitable projects are blocked at the level of state regulation. To ensure complete transparency and provide verified evidence for your legal and compliance services, we publish the originals of official requests and responses from state authorities. This is not a complaint, but an independent audit of the business environment.
Analysis of official responses (Ministry of Economy, National Academy of Sciences, Ministry of Foreign Affairs, State Committee for Standardization) reveals a fundamental gap between the strategic goals of the state and the actual infrastructure for business:
Direct creation of a classic export production in Belarus "turnkey" with access to global markets is today impossible due to strict adherence to internal EAEU norms and sanction restrictions.
However, the intellectual and raw material potential of the country remains colossal. Solving this problem requires not abandoning Belarus, but applying hybrid jurisdictional models (as in our project with China and the UAE), where Belarus serves as a centre of competence, R&D, and a safe bridge for Asian capital, while financial and logistics flows go through protected international hubs.
Belarus is a beautiful country in the centre of Europe with enormous human and raw material potential. We are convinced that the current institutional isolation and regulatory barriers are temporary. We openly share this experience so that the global business community understands the true architecture of risks and opportunities, and so that in the future these barriers are overcome for the benefit of the country's development and its integration into the world economy.