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EU trade sanctions in response to situation in Ukraine

On 3 June 2022, the EU adopted additional sanctions in response to Russia’s illegal and unprovoked military aggression against Ukraine. These sanctions build on, and expand, the earlier sanctions.

EU sanctions regulations have direct effect in all Member States of the EU, and, as such, are legally binding on all natural and legal persons in Ireland. Private companies, therefore, have an obligation to ensure that they are in full compliance with these new measures. A natural or legal person who contravenes a provision of an EU sanctions regulation shall be guilty of an offence and liable to prosecution.

This webpage summarises the key trade provisions of the EU sanctions enacted to date. The Department has also prepared an associated Guidance Notice.

Both the information on this page, and that which is contained in the Notice, are provided for information purposes only and do not constitute a legal interpretation of the EU Regulations. Traders should consult the EU Regulations directly, and when necessary, obtain professional advice.

This webpage and the Notice will be regularly reviewed, and while every effort has been made to ensure that the information is accurate, the situation is very dynamic and the sanctions, including the lists of prohibited goods, are liable to change.

Importation of goods using Russian-flagged vessels

From 16 April 2022 EU sanctions prohibit vessels registered under the flag of Russia from accessing EU ports. This also applies to vessels that have re-registered from the flag of Russia to the flag of another state after 24 February 2022.

The EU sanctions, make provision for a national Competent Authority (Department of Enterprise, Trade and Employment) to authorise a derogation from the prohibition on limited and very specific grounds. A derogation however, if authorised, would only permit the vessel to access an Irish port. It would be without prejudice to other sanctions measures that may prohibit or restrict the importation of the goods on the vessel. Furthermore, a derogation would only be considered when an importer has demonstrated that there is no feasible alternative at this time to making use of a vessel registered under the flag of Russia.

Under Article 3ea(5) of EU Regulation 833/2014 as amended, the Competent Authority may allow a derogation for a sanctioned vessel to access a port after having determined that the access is necessary for:

  • the purchase, import or transport of natural gas, oil, including refined petroleum products, as well as titanium, aluminium, copper, nickel, palladium and iron ore, as well as certain chemical and iron products as listed in Annex XXIV to the Regulation
  • purchase, import or transport of pharmaceutical and medical products, agricultural and food products, including wheat and fertilisers whose import, purchase and transport is permitted under the Regulation
  • humanitarian purposes
  • transport of nuclear fuel and other goods strictly necessary for the functioning of civil nuclear capabilities
  • the purchase, import or transport into the Union of coal and other solid fossil fuels, as listed in Annex XXII until 10 August 2022

Importers seeking a derogation on one of these grounds should complete the Derogation Application Form (Word document, 73KB) and submit it electronically to the relevant Government Department: 

Department of Agriculture, Food and the Marine 

feedimports@agriculture.gov.ie

Department of the Environment, Climate and Communications

energyimports@decc.gov.ie

Department of Health 

medicines_unit@health.gov.ie

If the relevant Department considers that a derogation is warranted, that Department will make a recommendation to the Department of Enterprise, Trade and Employment. The Department of Enterprise, Trade and Employment will then make the decision on whether to authorise the derogation and will notify the importer of the decision.

Trade sanctions adopted on 3 June 2022

The sixth package of EU sanctions came into effect on 4 June 2022 and the major trade-related elements of the package, which are set out in Council Regulation (EU) 2022/879 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:

I A ban on the importation of crude oil and petroleum products originating in Russia.

II An expansion of the list of goods and technology which may contribute to the technological enhancement of Russia’s defence and security sector and whose export is prohibited. This includes 80 chemicals which can be used to produce chemical weapons.

III An expansion of the list of items that generate significant revenues for Russia whose import into the EU is prohibited.

IV An expansion of the list of military-affiliated end-user entities in Russia and Belarus subject to tighter export restrictions.

V A ban on providing accounting; auditing; tax consulting; management consulting; and public relations services to entities established in Russia.

VI The exclusion of additional Russian and Belarusian financial institutions from the SWIFT payments system.

VII Further additions to the lists of Russian and Belarusian individuals and entities subject to financial sanctions.

NOTE: 1,186 Russian and 130 Belarusian individuals and entities are currently subject to financial sanctions. Therefore, traders should carry out thorough due diligence on all parties to a transaction to avoid inadvertently breaching the sanctions. 

Trade sanctions adopted on 8 April 2022

These sanctions came into effect on 9 April 2022 and the trade provisions, which are set out in Council Regulation (EU) 2022/576 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:

I An expansion of the categories of iron and steel products subject to an import ban.

II An expansion of the categories of luxury goods, subject to an export ban.

III An expansion of the categories of high-tech goods subject to an export ban, that might contribute to Russia’s military and technological enhancement.

IV A new import ban on a wide range of products and commodities, including wood, cement, chemicals and seafood, that generate significant revenues for Russia.

V A new import ban on coal and solid fossil fuels.

VI The introduction of import volume quotas for specified fertilizers, including potash.

VII A new export ban on an extensive list of low-tech goods, chemicals, commodities, and machinery, that might contribute to the enhancement of Russia’s industrial capabilities.

VIII A new export ban on jet fuel and fuel additives.

IX A new export ban on goods suited for use in liquefaction of natural gas.

X A ban on Russian-flagged vessels accessing EU ports.

XI A ban on Russian and Belarusian road transport operators transporting goods within the EU.

Exemptions may be authorised by National Competent Authorities (Department of Enterprise, Trade and Employment) from the shipping and road transport bans for imports of medical; agricultural; food; fertilisers; and energy products, and for specified metals and for humanitarian purposes.

Trade sanctions adopted on 15 March 2022

These sanctions came into effect on 16 March 2022 and the trade provisions are set out in Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:

I A prohibition on the import, purchase or transport of iron and steel products, as listed in the Regulation, which originate in Russia, or which have been exported from Russia.

II A prohibition on the sale, supply, transfer or export of specific luxury goods, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia.

III A prohibition on the sale, supply, transfer or export of specific goods and technology suited to use in oil exploration, production or refining, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia.

IV Additional restrictions on exports intended for use in Russia’s energy sector.

For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.

The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not. 

Trade sanctions adopted on 9 March 2022

These sanctions came into effect on 10 March 2022 and the trade provisions are set out in Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EC) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:

I A prohibition on the sale, supply, transfer or export of maritime navigation goods and technology, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia, or for placing on board of a Russian-flagged vessel.

II For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.

The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not. 

Trade sanctions adopted on 2 March 2022

These sanctions came into effect on 03 March 2022 and the trade provisions are set out in Council Regulation (EU) 2022/355 of 02 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus. These sanctions build on existing sanctions and were adopted in response to the involvement of Belarus in the Russian military aggression against Ukraine.

Previous sanctions against Belarus were introduced to address the forced landing of a flight in Minsk, Belarus on 23 May 2021 and the detention of two individuals by Belarusian authorities, as well as in response to the repeated failure of Belarus authorities to meet international electoral standards in Presidential elections and the crackdown on civil society and democratic opposition.

The major trade provisions of the Regulations are as follows:

I A prohibition on the sale, supply, transfer or export of dual-use* goods and technology to any natural or legal person, entity or body in Belarus or for use in Belarus.

II A prohibition on the sale, supply, transfer or export of goods and technology which might contribute to Belarus’ military, technological, defence and security enhancement, listed in the Regulation under the categories of electronics; computers; telecommunications and information security; sensors and lasers; navigation and avionics; marine; and aerospace and propulsion, to any natural or legal person, entity or body in Belarus or for use in Belarus.

III A prohibition on the sale, supply, transfer or export of specific machinery, listed in the Regulation, to Belarus or for use in Belarus. 

IV A prohibition on the sale, supply, transfer or export of goods used for the production or manufacturing of tobacco products, listed in the Regulation, to Belarus or for use in Belarus. 

V A prohibition on the import, purchase or transport of mineral products, potassium chloride (“potash”) products, wood products, cement products, iron and steel products and rubber products, as listed in the Regulation, which originate in Belarus or which have been exported from Belarus.

VI For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.

*Dual-use goods are items that have both a civilian and military application. They are identified in REGULATION (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.

The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not. 

Trade sanctions adopted on 25 February 2022

These sanctions came into effect on 26 February 2022 and the trade provisions are set out in Council Regulation (EU) 2022/328 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:

I A prohibition on the sale, supply, transfer or export of dual-use* goods and technology, to Russia or for use in Russia.

II A prohibition on the sale, supply, transfer or export, of specific goods and technology which might contribute to Russia’s military, technological, defence and security enhancement, listed in the Regulation under the categories of electronics; computers; telecommunications and information security; sensors and lasers; navigation and avionics; marine; and aerospace and propulsion, to Russia or for use in Russia.

III A prohibition on the sale, supply, transfer or export, of specific goods and technology, listed in the Regulation, suited for use in oil refining, to Russia or for use in Russia.

IV A prohibition on the sale, supply, transfer or export, of specific goods and technology, listed in the Regulation, suited for use in aviation or space industry, to Russia or for use in Russia.

V For each of the aforementioned prohibitions on exports of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.

*Dual-use goods are items that have both a civilian and military application. They are identified in REGULATION (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.

These prohibitions apply irrespective of whether the goods or technology originate in the EU or not. 

Trade sanctions adopted on 23 February 2022

The sanctions adopted by the EU on 23 February in response to the decision by the Russian Federation to recognise the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities, remain fully in effect. The sanctions include provisions restricting certain trading activities, both export and import, with the non-government controlled Ukrainian territories of Donetsk and Luhansk.

These sanctions came into effect on 24 February 2022 and the trade provisions are set out in Council Regulation (EU) 2022/263 concerning 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.

The Regulation provides that, for the specified territories of the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine,

I It is prohibited to import into the European Union goods originating in the specified territories.

II It is prohibited to sell, supply, transfer, or export specified goods and technology, listed in the Regulation, suited for use in the telecommunications, transport, energy and oil production sectors:

a) to any natural or legal person, entity or body in the specified territories, or
b) for use in the specified territories.

III It is prohibited to provide technical assistance or brokering services related to the goods and technology listed in the Regulation, or related to the provision, manufacture, maintenance and use of such items, to any natural or legal person, in the specified territories or for use in the specified territories.

IV It is prohibited to provide technical assistance, or brokering, construction or engineering services directly relating to infrastructure in the specified territories, in the telecommunications, transport, energy and oil production sectors, defined on the basis of the listed goods and technologies. This prohibition is independent of the origin of the goods and technology. 

Trade sanctions adopted in 2014

The Regulations cited above amend Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine, which was introduced in response to Russia’s illegal annexation of Crimea. 

Exemptions

The Regulations set out specific grounds on which the exporters can apply to the Competent Authority (Department of Enterprise, Trade and Employment) for a partial or temporary exemption from the prohibitions. These grounds include use in connection with humanitarian purposes, medical applications, software updates, and for the execution of contracts entered into prior to the sanctions coming into effect. However, the grounds for derogations are much narrower in respect of specific end-users, listed in the Regulation, affiliated with the Russian military. 

The requirements to avail of a derogation are precise and vary depending on the derogation being sought. Traders should closely study the details in the relevant EU Regulation. 

Further information

National

European Commission 

The European Commission has set up a secure, online platform to allow whistleblowers to anonymously report EU sanctions violations.

Queries regarding the trade provisions of EU sanctions should be sent to exportcontrol@enterprise.gov.ie

Topics: Export Licences