EU Enforces Certain Requirements for Sanctions on RU/BY

As of October 21, 2024, customs administrations in the European Union (EU) have started to enforce requirements related to the EU sanctions on Russia (RU) and Belarus (BY).

Customs now requires that for all export declarations for goods destined to third countries, except Australia, Canada, Switzerland, United Kingdom, Iceland, South Korea, Liechtenstein, Norway, New Zealand, Japan and the United States of America, exporters must indicate in the export declaration that they comply with paragraph 1 of Article 12g of Council Regulation (EU) No 833/2014 and paragraph 1 of Article 8g of Council Regulation (EC) No 765/2006. These articles require exporters to contractually prohibit re-exportation to Russia or Belarus or re-exportation for use in Russia or Belarus.

In order to present a compliant export declaration to customs, the exporter needs to confirm which of the following conditions apply to the export transaction:

1. A contract is in place that fulfills the requirements of the mentioned provisions;
2. The requirements set out in the mentioned provisions do not apply (please refer to contractual exemptions provided for in the relevant regulations);
3. The export transaction is a consequence of procurement by a public authority of a third country or with an international organization; or
4. The export transaction covers goods not subject to the prohibitions defined in Article 3c of Council Regulation (EU) No 833/2014 and Article 1sa.1 of Council Regulation (EC) No 765/2006.

No official announcement by customs authorities has been issued in this regard.

Please contact your Customs and/or Compliance contact at Expeditors should you require further guidance.