Adoption of the 20th Sanctions Package against Russia

Major tightening of trade restrictions:
• Export restrictions to Russia are extended to new goods and services, including rubber, chemicals, lubricants, laboratory glassware, as well as certain cybersecurity services and technologies and materials used on the battlefield, including those used in the production of explosives.
• New import restrictions apply to metals, chemicals and critical minerals (natural magnesium carbonate, iron ores, sodium hydroxide, other articles of unvulcanised rubber, waste and scrap of cast iron, iron or steel, unrefined copper, nickel bars, profiles and wires, aluminium waste and scrap, etc.).
• A specific requirement applies to diamonds classified under CN code 7102 39 00, which must be accompanied by a due diligence statement confirming that they are not extracted, processed or produced in Russia.

These new measures are intended to directly target Russia’s industrial and military capabilities.

Activation of the anti-circumvention tool provided for in Article 12f of Regulation (EU) No 833/2014

This is a key development in this sanctions package, as for the first time since the 11th package, the European Union will activate this mechanism aimed at prohibiting the export of sensitive goods and technologies to certain third countries identified as presenting a high risk of re-export to Russia.

In practice, this means:
• A prohibition on selling, supplying or exporting the goods listed in Annex XXXIII to the countries concerned;
• A prohibition on providing technical assistance, brokerage, maintenance or financing services related to these goods;
• A prohibition on transferring associated intellectual property rights or trade secrets.

For the time being, Annex XXXIII applies only to products classified under CN codes 8457 10 and 8517 62 when exported to the Kyrgyz Republic.

In this context, companies must enhance their vigilance over trade flows and ensure strict control over the end-use and final destination of goods.