EU sanctions on Russia and Belarus: what exporters should check
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The EU has adopted 21 packages of restrictive measures against Russia, the latest on 23 July 2026. The trade measures are in Regulation (EU) No 833/2014 for Russia and Regulation (EC) No 765/2006 for Belarus. They do not only affect direct shipments, but also those routed through third countries.
Legal text
Regulation (EU) No 833/2014, Article 12g(1) (inserted by Regulation (EU) 2023/2878)
When selling, supplying, transferring or exporting to a third country, with the exception of partner countries listed in Annex VIII to this Regulation, goods or technology as listed in Annexes XI, XX and XXXV to this Regulation, common high priority items as listed in Annex XL to this Regulation, or firearms and ammunition as listed in Annex I to Regulation (EU) No 258/2012, exporters shall, as of 20 March 2024, contractually prohibit re-exportation to Russia and re-exportation for use in Russia.
What the sanctions prohibit
The list of products that cannot be exported to Russia or Belarus is long and includes dual-use goods, advanced technology, machinery, industrial goods and luxury goods, among others. Each product is identified by its CN code in the annexes, so correct tariff classification is the first check.
Importing certain Russian products into the EU, such as steel, wood or cement, is also prohibited, as is dealing with persons and entities on the sanctions lists. In transport, for example, Russian and Belarusian road hauliers may not carry goods within the EU.
The no re-export clause
Since 20 March 2024, anyone selling common high priority items (Annex XL), aviation goods, jet fuel or firearms to a buyer outside the EU must include in the contract an express prohibition on re-exporting them to Russia or for use in Russia, with consequences for breach. Partner countries listed in Annex VIII are exempt. This is Article 12g of Regulation No 833/2014.
Shipments to third countries
Authorities focus on destinations used to re-export to Russia. In the 20th package, in April 2026, the EU used its anti-circumvention tool for the first time and banned exports of CNC machines to Kyrgyzstan. The 21st package added entities in several third countries to the list.
It is worth stopping to check when the buyer is in a country neighbouring Russia with no clear business link to the goods, when the destination or consignee changes at the last minute, when a third party other than the buyer pays, or when an Annex XL item is going to an unclear end user.
Checks before every shipment
- Exact CN code of the goods, compared with the current annexes.
- Buyer, consignee and end user, compared with the sanctions lists (EU Sanctions Map).
- Article 12g clause in the contract where it applies.
- Consistency between invoice, packing list, transport document and declared destination.
How we help
This is not legal advice. Compliance is the exporter's responsibility, and licensing questions go to the Spanish Secretary of State for Trade.
Before accepting a shipment to a higher-risk destination we review the goods, the route and the parties with you, and we do not handle operations that could breach sanctions.
Ask us about your shipmentOfficial sources
- Consejo de la UE: cronología de las sanciones contra Rusia
- EU Sanctions Helpdesk: 21.º paquete de sanciones
- EUR-Lex: Reglamento (UE) 2023/2878 (introduce el artículo 12 octies)
- Comisión Europea: preguntas frecuentes sobre la cláusula de no reexportación a Rusia
- EU Sanctions Map: listas y medidas vigentes
General information, not legal advice. Regulations change often, so always check the current text in the official sources.