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Taxation and Customs Union

EU measures following the Russian invasion of Ukraine

Information for customs authorities and stakeholders

Following Russia’s invasion of Ukraine, the EU has put in place a list of restrictive measures to respond to Russian aggression and in support of and solidarity with Ukraine. Many of these measures have implications for the work of EU customs authorities, importers and exporters.

A full guidance Q&A document is available here(last update: 1 June 2022).

Restrictive measures

On 23 February 2022, in response to Russia’s military aggression against Ukraine, the EU introduced restrictive measures on economic relations with the non-government controlled areas of the Donetsk and Luhansk oblasts. The EU then decided to extensively expand sanctions on 24 and 25 February. Further sanctions were introduced on 28 February, 2, 9 and 15 March 2022. The latest round of sanctions (the fifth package) were adopted on 8 April.

Packages I, II, III and IV

List of measures against the Russian Federation

From a customs perspective, several export restrictions will have an impact, namely:

Sell, supply, transfer or export:

  • Expansion of the restrictive measures already in place since 2014 on the exports of dual-use goods and technology to all end-users, including non-military.
  • military goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector. Related technical or financial assistance and services are also prohibited.
  • goods and technology suited for use in aviation or the space industry, as listed in Annex XI of Regulation (EU) 833/2014, to any person or entity in Russia or for use in Russia. It is also prohibited to provide any related insurance and reinsurance and certain related activities. Related technical or financial assistance and brokering or other services are also prohibited.
  • luxury goods, as listed in Annex XVIII of Regulation (EU) 833/2014, to any person or entity in Russia or for use in Russia.
  • maritime navigation goods and technology, as listed in Annex XVI of Regulation (EU) 833/2014, to any person or entity in Russia, for use in Russia or for the placing on board of a Russian-flagged vessel. Related technical or financial assistance and brokering or other services are also prohibited.
  • goods and technology suited for use in oil refining, as listed in Annex X of regulation (EU) 833/2014, to any person or entity in Russia or for use in Russia. Related technical or financial assistance and brokering or other services are also prohibited.
  • certain equipment listed in Annex II of Council Regulation 833/2014 shall be subject to prior authorisation by the competent authority of the exporting Member State.

Import, purchase or transfer:

  • arms and related materials from Russia.
  • iron and steel products, as listed in Annex XVII of Regulation (EU) 833/2014, from Russia. Related technical or financial assistance and brokering services are also prohibited.

List of measures against the Republic of Belarus

List of measures were also addressed against Belarus, covering both exports and imports, namely:

Sell, supply, transfer or export:

  • Expansion of the restrictive measures already in place on the exports of dual-use goods and technology to all end-users, including non-military.
  • military goods and technology, which might contribute to Belarus's military and technological enhancement, or to the development of its defence and security sector, as listed in Annex Va of Regulation (EC) 765/2006, to Belarus. Related technical or financial assistance and brokering or other services are also prohibited.
  • equipment which might be used for internal repression. Related technical or financial assistance and services are also prohibited. Derogations subject to specific conditions exist for (a) biathlon rifles, ammunition and sights, and (b) small-calibre sporting rifles, small-calibre sporting pistols and ammunition.
  • machinery (ex: engines, furnaces, bulldozers, lift-trucks), as listed in Annex XIV of Regulation (EC) 765/2006, to any person or entity in Belarus or for use in Belarus. Related technical or financial assistance and brokering services are also prohibited.
  • equipment, technology or software intended primarily for use in the monitoring or interception by the regime of Belarus of the internet and of telephone communications on mobile or fixed networks in Belarus as listed in Annex IV of Regulation (EC) 765/2006. It is also prohibited to provide telecommunication or internal monitoring or interception services and related financial and technical assistance.
  • goods used for the production or manufacturing of tobacco products, as listed in Annex VI of Regulation (EC) 765/2006, in Belarus.

Import, purchase or transfer:

  • cement products, as listed in Annex XI of Regulation (EC) 765/2006. Related technical or financial assistance and brokering services are also prohibited.
  • iron and steel products, as listed in Annex XII of Regulation (EC) 765/2006. Related technical or financial assistance and brokering services are also prohibited.
  • mineral products, as listed in Annex VII of Regulation (EC) 765/2006. Related technical or financial assistance and brokering services are also prohibited.
  • potassium chloride (“potash”) products, as listed in Annex VIII of Regulation (EC) 765/2006.
  • rubber products, as listed in Annex XIII of Regulation (EC) 765/2006. Related technical or financial assistance and brokering services are also prohibited.
  • wood products, as listed in Annex X of Regulation (EC) 765/2006, from Belarus. Related technical or financial assistance and brokering services are also prohibited.

Package V, 08 April 2022

In light of Russia’s continued war of aggression against Ukraine, and the reported atrocities committed by Russian armed forces in Ukraine, the EU adopted on 8 April 2022 a fifth package of economic and individual sanctions against Russia (legal texts available here).

The fifth package comprises both updates/extension of the scope coverage of existing measures as well as completely new restrictive measures.

Key points of relevance for customs:

Russia

  1. Extension/adjustment of the scope of existing measures affecting import and exports of goods from and to Russia
    • Extends the list of items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector, banned from export,
    • Extends the export ban ongoods and technology suited for use in oil refining to goods and technology for the liquefaction of natural gas,
    • Extends the export ban ongoods and technology suited for use in aviation or the space industry to jet fuel and fuel additives,
    • Extends the list of luxury goods, banned from export,
    • Reduces the derogations possibilitieson the export bans on dual-use items and items which might contribute to Russia’s military and technological enhancement; 
    • Introduces an import ban on goods generating revenue for Russia (fertilisers, cement, wood, glass products...). Derogations are possible until 10 July in case of prior contractual commitment,
    • Introduces an import ban on coal and other solid fossil fuels. Derogations are possible until 10 August in case of prior contractual commitment,
    • Introduces an exportban on goods, which could contribute to the enhancement of Russian industrial capacities (chemicals, wood, textiles, construction material, metals, machinery...). Derogations are possible for diplomatic reasons, or until 10 July in case of prior contractual commitment. Export can be authorised for humanitarian reason.
    • Extends the prohibition to sell, supply, transfer or export to Russia Euro banknotes to banknotes denominated in all Member States official currencies,
    • Introduces  a derogation from the prohibition to transfer or export luxury goods to Russia. For cultural goods which are on loan in the context of formal cultural cooperation with Russia, competent authorities may authorise their transfer or export to Russia. Commission must be informed of this authorisation within two weeks. 
  2. New measures not included in previous sanctions packages
    • a prohibition to provide access, after 16 April 2022, to EU ports to vessels registered under the flag of Russia. Certain limited derogations are granted for specific goods (e.g. agricultural and food products, humanitarian aid, and energy) or specific use of the vessel;
    • a ban on any Russian and Belarusian road transport undertaking preventing them from transporting goods by road within the EU, including in transit. Certain limited derogations are granted for: undertakings transporting mail as a universal service; goods in transit though the Union between the Kaliningrad Oblast and Russia, provided that the transport of such goods is not otherwise prohibited under this Regulation; until 16 April 2022 for transport of goods that started before 9 April 2022. In addition, competent authorities of a Member State may authorise derogations for the transport of certain goods (e.g. goods natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron, etc.)        

Belarus

The new package comprises both updates/extension of the scope coverage of existing measures as well as completely new restrictive measures. Key points of relevance for customs:

  • imposes further restrictive measures prohibiting the sale to Belarus of transferable securities denominated in any official currency of a Member State, and prohibiting the sale, supply, transfer or export to Belarus of banknotes denominated in any official currency of a Member State;
  • further restrictive measures prohibiting road transport undertakings established in Belarus from transporting goods by road within the territory of the European Union.

Similar derogations are envisaged for Belarus as for Russia.

Package VI, 03 June 2022

The Sixth Package imposes further sanctions against the Russian Federation and Belarus, considering its involvement in the aggression of Russia against Ukraine. The package was adopted on 3 June 2022 as a Sixth  Package of economic and individual sanctions (legal texts available here).

The sixth package comprises both updates/extension of the scope coverage of existing measures as well as new restrictive measures. The package contains a complete import ban on all Russian seaborne crude oil and petroleum products. The ban is subject to certain transition periods. As regards export restrictions, today's package includes restrictions on chemicals that could be used in manufacturing chemical weapons.

Key points of relevance for customs:

Oil import restrictions

  • The customs authorities of the European Union’s Member States have been advised to take all necessary measures and to exercise particular diligence in order to mitigate the risk of circumvention of the Russian import sanctions on crude oil through the blending with oil originating in third countries. In particular, they will request documentary or other appropriate evidence that the oil shipments do not contain oil of Russian origin.

  • In 2021, the EU imported €48 billion worth of crude oil and €23 billion of refined oil products from Russia. Based on a joint proposal from the High Representative (of the Union for Foreign Affairs and Security Policy) and the Commission, Member States have today decided to impose an embargo on the imports of these products. These sanctions will come into force with immediate effect, and will phase out Russian oil imports in an orderly fashion. For seaborne crude oil, spot market transactions and execution of existing contracts will be permitted for six months after entry into force, while for petroleum products, these will be permitted for eight months after entry into force. Member States who have a particular pipeline dependency on Russia can benefit from a temporary exemption and continue to receive crude oil delivered by pipeline, until the Council decides otherwise. However, Member States benefiting from this exemption will not be able to resell such crude oil and petroleum products to other Member States or third countries.
  • Due to its specific geographical exposure, a special temporary derogation until the end of 2024 has been agreed for Bulgaria which will be able to continue to import crude oil and petroleum products via maritime transport. In addition, Croatia will be able to authorise until the end of 2023 the import of Russian vacuum gas oil which is needed for the functioning of its refinery.
  • On 3 August, a notice to operators was published which clarified that imports of Russian crude oil or petroleum products into the Union transported together with oil of other origin in mixed form is subject to the prohibition, unless the exact share of the product which does not originate in Russia can be clearly demonstrated to the national authorities of the Member State. In such a case, the exact portion of oil not originating in Russia can be allowed into the Union.

Oil transport services

  • After a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries.

Export restrictions

  • The Sixth Package includes further export restrictions. The list of advanced technology items banned from export to Russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons, already controlled since 2013 for other destinations such as Syria. Moreover, today's package further expands the list of natural, legal persons or entities associated with Russia's military-industrial complex. These natural, legal persons or entities are involved in various sectors, such as electronics, communications, weapons, shipyards, engineering and scientific research. This update brings the EU in alignment with United States measures, while other partners are expected to align in the near future.
  • The package adds the United Kingdom and the Republic of Korea to the Annex of partner countries that have adopted substantially equivalent export restrictions.
  • The list of Belarusian entities subject to restrictions has been significantly widened (from 1 entity to 25). This is related to authorisations for the sale, supply, transfer or export of dual-use goods and technology, as well as goods and technology which might contribute to Belarus's military and technological enhancement, or to the development of its defence and security sector.

Package VII, 21 July 2022

On 21 July 2022, the Council adopted measures intended to tighten existing economic sanctions targeting Russia and Belarus, perfect their implementation and strengthen their effectiveness. It is so called “maintenance and alignment” package.

Key points of relevance for customs:

Import, purchase or transfer

The package introduces a new prohibition to purchase, import, or transfer, (directly or indirectly):

  • gold, if it originates in Russia and it has been exported from Russia into the EU or to any third country after.
  • jewellery, if it originates in Russia and it has been exported from Russia into the EU or to any third country after. Exception for personal use).

The ban is subject to certain transition periods.

Export, list of controlled items

The list consists of items which may contribute to Russia’s military and technological enhancement or the development of its defence and security sector.

Expansion of list of advanced technology items (50 additional items), including:

  • including special materials and related equipment (i.a., special fibres, used in aircraft, or the equipment used to produce them),
  • manufacturing equipment (i.a., machine tools that can be used to produce industrial components or weapons),
  • other items, such as those used for law enforcement, such as helmets and batons, or chemicals used in riot control,
  • limited number of vaccines refers only to vaccines against pathogens included in the dual-use list (under 1C351, included in Regulation (EU) 833/2014, Annex VII – e.g. variola virus, yellow fever, MERS-corona, etc.

Additional listings

Additional individuals and entities have been sanctioned (54 people and 9 entities).

Other relevant new provisions:

  • the Council decided to strengthen reporting requirements, putting the burden of declaring assets onto sanctioned people, in order to facilitate the freezing of their assets in the EU.
  • Extension of prohibition to access to locks by ships. The extension of the port access ban to locks aims to stop possible circumvention of the sanctions through canals.
  • Extended exemptions. New exemptions from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the transport of oil to third countries.

Package VIII, 06 October 2022

The eighth Package imposes further sanctions against the Russian Federation and Belarus, considering its involvement in the aggression of Russia against Ukraine. The package was adopted on 6 October 2022.

This package introduces new EU import bans to curb Russia's revenues, as well as export restrictions, which will further deprive the Kremlin's military and industrial complex of key components and technologies and Russia's economy of European services and expertise.

The package also lays the basis for the required legal framework to implement the oil price cap envisaged by the G7.

Key points of relevance for customs:

Import restrictions

Additional import restrictions have been agreed. It includes:

  • a ban on the import of Russian finished and semi-finished steel products (subject to a transition period for some semi-finished),
  • machinery and appliances,
  • plastics,
  • vehicles,
  • textiles,
  • footwear,
  • leather,
  • ceramics,
  • certain chemical products,
  • non-gold jewellery.

Export restrictions

Additional export restrictions have been introduced. This includes:

  • the banning of the export of coal including coking coal (which is used in Russian industrial plants),
  • specific electronic components (found in Russian weapons),
  • technical items used in the aviation sector,
  • certain chemicals.
  • a prohibition on exporting small arms and other goods under the anti-torture Regulation has been added.

Additional listings

Additional individuals and entities have been sanctioned. It also includes individuals and entities working in the defence sector, such as high-ranking and military officials, as well as companies supporting the Russian armed forces.

The package bans all transactions with the Russian Maritime Register, adding it to the list of state-owned enterprises which are subject to a transaction ban.  

Extension of restrictions to the oblasts of Kherson and Zaporizhzhia

The geographical scope of the restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas has been extended to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kherson.

Implementing the G7 oil price cap

The package marks the beginning of the implementation within the EU of the G7 agreement on Russian oil exports. While the EU's ban on importing Russian seaborne crude oil fully remains, the price cap, once implemented, would allow European operators to undertake and support the transport of Russian oil to third countries, provided its price remains under a pre-set “cap”.

It would take effect after 5 December 2022 for crude and 5 February 2023 for refined petroleum products, after a further decision by the Council.

Deterring sanctions circumvention

The EU has introduced a new listing criterion, which will allow it to sanction persons who facilitate the infringements of the prohibition against circumvention of sanctions.

    Risk of circumvention

    To prevent the circumvention of these measures, the Commission has published notices informing importers and exporters that they should take due diligence measures to avoid that the goods they export and which are subject to sanctions end up in Russia or Belarus, or that the goods they import from other countries, e.g. members of the Eurasian Economic Union, are not actually originating in Russia or Belarus and thus subject to sanctions. These measures include, for instance, the introduction in import and export contracts of provisions destined to ensure that any imported or exported goods are not covered by the restrictions.

    Links to Notices:

    Imports of goods originating in the Donetsk and Lugansk oblasts

    First, the Commission prepared a list of measures in reply to the Russian attempt to illegally annex the two Ukrainian regions Luhansk and Donetsk, which included a ban on imports from these two occupied territories as well as some export restrictions (on dual use goods) to the same territories. A notice to importers was published and updated recently Notice (2022/C 458/02) warning importers about the risk of circumvention of the import ban via Russia and Belarus and indicating that customs may request conclusive evidence from importers that imports from Russia and Belarus, in particular of coal and steel, are not from the regions for which the ban applies.

    The regulations ban the direct or indirect import or export of the concerned goods, and prohibit the participation, knowingly and intentionally, in activities to circumvent these prohibitions. Any infringement of the regulations is subject to sanctions to be applied by Member States. Therefore, importers and exporters must also take adequate due diligence measures in order to limit a risk of circumvention of sanctioned goods from to/from the Russian Federation or the Republic of Belarus.

    Transit of Goods

    On 13 July 2022, the Commission published further guidance to Member States on the transit of goods from Russia. The guidance specifies the applicable rules and recalls that Member States are obliged to prevent all possible forms of circumvention of EU restrictive measures. In that light, the Commission underlines the importance of monitoring the two-way trade flows between Russia and Kaliningrad Oblast to ensure that sanctions are not circumvented.

    Legal texts relevant for customs

    Russia

    Belarus

    Ukraine (non-government controlled areas)

    Related information