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Russia-Ukraine Emergency Russia-Ukraine Emergency

The war between Russia and Ukraine continues, and restrictions are still being applied regarding the transportation and shipment of goods.

On March 15, 2022, the latest EU Implementing Regulation 2022/427 , was published, which provides:

  • Trade restrictions on luxury goods: The prohibition applies to the direct or indirect sale, supply, transfer, and export of listed goods with a value exceeding 300 euros per item unless otherwise specified. For each items are applied the following thresholds: 50,000 euros for vehicles, 5,000 euros for motorcycles, 1,500 euros for musical instruments, 750 euros for electronic equipment for household use.
  • Steel and iron: prohibition of import, purchase and transportation (direct or indirect) of steel and iron originating or exported from Russia and prohibition of provision of associated services.
  • Prohibitions on new investments in Russia’s energy sector, as well as a general restriction on exports of equipment, technology and services for the energy sector to Russia, with the exception of the nuclear industry and the downstream energy transportation sector (oil and gas). Exceptions are made to allow transactions deemed “critical to the EU’s energy supply.”
  • The prohibition of transactions with some Russian public companies.
  • On the financial side: a ban from April 15, 2022 on the provision of credit rating services to any person, as well as access to subscription services related to credit rating activities, to any Russian person or organization and public office.

In addition, EU Regulation 428/2022,also came into force on March 16, 2022, leading to further restrictions on exports to Russia:

  • Art. 3 (amending Art.3 of reg 833/2014): prohibition to sell, supply, transfer or export, directly or indirectly, goods or technologies listed in Annex II of reg 833/2014, including those not originating in the Union, to any natural or legal person, entity or body in Russia, including its exclusive economic zone and continental shelf, or for use in Russia, including its exclusive economic zone and continental shelf.
  • Article 3g 1. : It’s prohibited: a) to import into the Union, directly or indirectly, steel products listed in Annex XVII if: (i) they originate in Russia; or (ii) they have been exported from Russia; (b) to purchase, directly or indirectly, the steel products listed in Annex XVII located in Russia or originating in Russia; (c) to transport the steel products listed in Annex XVII originating in Russia or exported from Russia to any other country; (d)provide, directly or indirectly, technical assistance, brokering services, financing or financial assistance, including financial derivatives, insurance and reinsurance relevant to the prohibitions in (a), (b) and (c) above.
  • Art. 3 nonies:
    1.It is prohibited to sell, supply, transfer or export, directly or indirectly, luxury goods listed in Annex XVIII to any natural or legal person, entity or body in Russia, or for use in Russia.
    2. The prohibition in paragraph 1 shall apply to luxury goods listed in Annex XVIII to the extent that their value exceeds EUR 300 per item, unless otherwise specified in the Annex.
    3.The prohibition referred to in paragraph 1 shall not apply to goods that are necessary for official purposes of diplomatic or consular missions of member states or partner countries in Russia or international organizations that enjoy immunities in accordance with international law or personal effects of their personnel.”