EU: Eleventh package of sanctions against Russia includes trade, transport, and energy measures

The European Commission today announced that the European Council has approved an eleventh package of sanctions against Russia for its aggression against Ukraine.

According to today’s EC release, key elements in the package contains:

• A new anti-circumvention tool that will allow the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention
• Extension of the transit prohibition for certain sensitive goods (e.g., advanced technology, aviation-related materials) exported from the EU to third countries, via Russia
• Addition of 87 new entities to the list of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They are subject to tighter export restrictions for dual-use and advanced technology items. In addition to the Russian and Iranian entities already listed, this now also covers entities registered in China, Uzbekistan, the United Arab Emirates, Syria, and Armenia.
• Restriction on the exports of further 15 technological items found on the battlefield in Ukraine or equipment needed to produce such items
• Tightening restrictions on imports of iron and steel goods by requiring importers of sanctioned iron and steel goods that have been processed in a third country to prove that the inputs used do not come from Russia
• Prohibition to sell, license, transfer or refer intellectual property rights and trade secrets used in connection with restricted goods to prevent the sanctioned goods from simply being manufactured outside the EU
• Extension of the ban on export of luxury cars to all new and second-hand cars above a certain engine size, and all electric and hybrid vehicles
• A full ban on certain types of machinery components
• Simplifying the structure of the industrial goods annex, by listing products subject to restrictions in one single section and with broader product definitions, to better identify goods subject to export bans and reduce circumvention of sanctions by misclassification

• A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU
• Prohibition to access EU ports for vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 Coalition price cap
• Prohibition to access EU ports for vessels if a vessel does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State's coast
• Prohibition to access EU ports for vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap

• End of the possibility to import Russian oil by pipeline for Germany and Poland
• Insertions of strict and very targeted derogations to the existing export bans to enable the maintenance of the CPC (Caspian Pipeline Consortium) pipeline which transports Kazakh oil to the EU through Russia
• Extension of the exception to the oil price cap for Sakhalin oil for Japan (until 31 March 2024)

The European Commission also released a set of “questions and answers” (Q&As) on the eleventh package of restrictive measures against Russia.

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