The 12th EU sanctions package introduces new import and export sanctions and tighter transit bans

The 12th sanctions package imposed by the European Union continues to expand the import and export restrictions aimed at Russia. The package also enables new means for detecting attempts at circumventing sanctions, for example through more intense transit bans.

The latest EU sanctions package introduces ever-stricter export prohibitions on products that could serve Russia’s military, industrial and technological capabilities. Products added under sanctions include chemicals, lithium batteries, thermostats, motors for unmanned aerial vehicles, machine tools and machinery parts that Russia has used in developing its military systems or in the war of attack against Ukraine.

As concerns import sanctions, the list introduces further restrictions on imports of goods that generate significant revenues for Russia, such as liquefied propane gas, pig iron, copper wires and certain aluminium products. Moreover, Russian diamonds are now sanctioned.

Instructions by the Commission regarding the ban on importing Russian-registered vehicles to the EU is also now included in the newly imposed sanctions regulation.

Corporate responsibility in a significant role in preventing circumvention of sanctions

For preventing circumventions, the latest sanctions package contains an expanded  list of sanctioned goods as regards transports to third countries via Russia. Certain product categories already under export bans and deemed to serve Russia’s industrial development are now prohibited from transit as well. From now on, transports through Russia of for example components of diesel engines, excavators, portable computers, hydraulic and pneumatic components and crane lorries are prohibited (Annex XXXVII). 

The previously implemented sanctions packages have already prohibited transits of all high-technology products (Annex VII), aviation and space technology products (Annex XI), aviation fuels (Annex XX), as well as dual-use products, firearms and related supplies covered by the sanctions regulation.

In the future, exporters of certain products must include an obligation in their trade contracts requiring purchasers to prevent products from ending up in Russia as re-exports, or in Russia’s reach by some other means. Such products include aviation and space industry products and technology, aviation fuels, firearms and related supplies, as well as many types of electronics such as microprocessors, radio navigation devices and radio remote control devices (Annexes XI, XX, XXXV and XL). Weapons and ammunitions listed in Annex I are also among the products.

– Strong EU-level cooperation and harmonised enforcement of sanctions are important in preventing circumventions of sanctions. By those means, we can combat attempted circumventions as efficiently as possible. However, we as authorities can only do our own share of things. Businesses have indeed a significant responsibility in preventing circumventions, and for ensuring that sanctions have the appropriate effect. This is why businesses must know their trading partners and verify the ultimate destinations of goods, says Mr Sami Rakshit, Director of the Enforcement Department.

The new EU sanctions were published in the Official Journal of the European Union on 18 December 2023. The sanctions package entered into force at midnight on Tuesday, 19 December.

Press release by the Ministry for Foreign Affairs (18 December 2023): 12th package of sanctions tightens foreign trade restrictions and introduces new measures to combat sanctions circumvention