Export bans to Russia

European Union states have adopted several regulations prohibiting the export, sale, or supply, directly or indirectly, of the following goods:

• dual-use goods and technologies (dual-use goods);
• goods and technologies that could contribute to the development or strengthening of Russia in the military or technological field;
• goods for the oil industry;
• aerospace goods;
• products of the maritime industry (vessels, naval systems, etc.);
• luxury goods (e.g. leather goods, watches, jewellery, selected goods of Chapters 84 and 85, sports equipment, carpets, etc.).

There are some exceptions to the above-stated prohibitions. Nevertheless, given the narrow definition of these exceptions, it is advisable to study them carefully.

In the case of the ban on the export of luxury goods, the goods are defined not only by their description and tariff classification but also by their value per item.

A ban on the import, transport, or purchase of selected iron and steel products of Chapters 72 and 73 of the Customs Tariff has also been introduced.

Bans on export to/import from Belarus

Specifically, export, sale, or supply was prohibited of the following goods:

• dual-use goods and technology;
• goods and technologies that could contribute to the development or strengthening of Belarus in the military or technological field;
• selected machinery and equipment.

In addition, a ban on import, transport, or purchase has been introduced:

• cement and cement products of customs codes 2523 and 6811;
• new rubber tyres of customs code 4011;
• wood products of Chapter 44 of the Customs Tariff;
• iron and steel of Chapter 72 of the Customs Tariff;
• iron and steel products of Chapter 73 of the Customs Tariff.

Bans on export to/import from Donetsk and Luhansk

Due to the recognition of independence and the subsequent loss of Ukraine’s control over the territory of the Donetsk and Luhansk regions, EU countries have restricted trade with these regions.

Specifically, imports of goods originating in these territories are prohibited, with exceptions provided for by the Regulation. In the context of the ban on imports from these areas, the first attempts to circumvent these sanctions have already been noted. Customs authorities are thus introducing more thorough checks on the actual origin of shipments.

In addition, the export, sale, supply, or transfer of goods and technology intended for or suitable for use in the transport, telecommunications, energy, oil, gas, and minerals sectors is prohibited.

Conclusion and recommendations

Given the fact that import and export conditions can change from day to day, we recommend that you regularly monitor the latest developments in this area.

We also suggest that you scrutinise your trading partner, review the lists of goods that are prohibited to import or export and verify the destination of the product you are exporting. If you are importing goods from Ukraine, it is advisable to ensure that you have sufficient evidence in advance proving the goods do not originate from Donetsk or Luhansk.

The issue of bans on imports and exports of goods from/to Russia, Belarus, Luhansk, and Donetsk is changing dramatically. We are ready to assist you in this regard and to verify that your business transactions are not in violation of sanctions that have been or will be imposed. Please do not hesitate to contact us at any time in this regard.