- Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 (“Regulation 745” and “Regulation 833” respectively); and
- Council Implementing Regulation (EU) 2024/753 of 23 February 2024 implementing Regulation (EU) No 269/2014 (“Regulation 753” and “Regulation 269” respectively).
Extension of the list of goods prohibited for export to Russia
The EU continues to extend the list of items that are subject to export restrictions.More specifically, the list of goods prohibited for export to Russia includes:
- aluminium capacitors which are designated as goods that “contribute to Russia’s military and technological enhancement or the development of the defence and security sector” (Annex VII (Part B) of Regulation 833); and
- electrical transformers, static converters (for example, rectifiers) and inductors which are designated as goods that “contribute to the enhancement of Russia’s industrial potential” (Annex XXIII of Regulation 833).
Exemption of a number of goods from export restrictions to Russia
The EU introduced a temporary exemption in respect of the export of certain goods that were listed as goods that “contribute to the enhancement of Russia’s industrial potential” for the purpose of completing export-associated transactions. According to the new paragraph 3ac of article 3k of Regulation 833, export prohibitions shall not apply to certain categories of goods (such as ballasts for discharge lamps or tubes, liquid dielectric transformers, static converters, etc.) where this is necessary for the performance until 25 May 2024 of contracts concluded before 24 February 2024.Extension of the list of persons connected with Russia’s military and industrial complex
Twenty-seven legal entities which, in the EU’s opinion, “are military end-users, form part of Russia’s military and industrial complex or which have commercial or other links with or which otherwise support Russia’s defence and security sector” were included in Annex IV of Regulation 833. This is the first time that listed entities include companies from India, Kazakhstan, Serbia, Thailand, Türkiye and Sri Lanka. As noted in the European Commission’s press release, these companies were discovered to have traded in electronic components, including components of a European origin. Being on this list means that a company cannot obtain authorisation to export dual-use goods or technology or goods and technology that “contribute to Russia’s military and technological enhancement or the development of the defence and security sector” (articles 2(7) and 2a(7) of Regulation 833), except when such goods or technology is needed for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment (article 2b(1) of Regulation 833).The UK as a partner country for sanctions on iron and steel imports
Along with Norway and Switzerland, the UK has been added to the list of partner countries that apply sanctions in respect of steel and iron imports that are substantially equivalent to those of the EU. We discussed those restrictions earlier. These partner countries for iron and steel imports apply a set of equivalent restrictive measures and controls on the imports of iron and steel originating from Russia. The inclusion of the UK on the list of partner countries implies that if steel and iron products are imported or transported to the EU from the UK, there is no need to produce proof of origin of goods, as the UK itself applies a number of measures to control the imports of such goods of Russian origin.EU’s blocking sanctions
Council Regulation 753 has extended the list of persons who are subject to restrictive measures stipulated by Regulation 269. The updated list now includes 106 legal entities and 88 individuals who mainly operate in the military-industrial and logistics sectors in Russia.The EU further continues to impose sanctions on the grounds introduced by the 11th package against persons “otherwise significantly frustrating sanctions against Russia”.
Novelco LLC which, according to the EU Council, imports sanctioned goods to Russia as part of “parallel imports” and its general director Mr G.I. Grigoriev were designated as sanctioned persons.
