What Cannot Be Imported from Russia as of February?

30 November 2022

In recent days the media have carried inaccurate reports about sanctions on Russian-origin LPG supposedly taking effect on 5 February 2023. What did the European Union actually adopt?

On 3 June 2022 the European Union adopted its 6th package of sanctions against Russia and Belarus. The detailed provisions are set out in Council Regulation (EU) 2022/879 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine.

The 6th package of sanctions includes, among other things, a ban on the purchase, import or transfer to Member States, directly or indirectly, of crude oil (CN code 2709 00) and of certain petroleum products (CN code 2710) that originate in Russia or have been exported from Russia. A ban was also introduced on insurance and reinsurance of the maritime transport of such goods to third countries. Importantly, at the request of some Member States, the sanctions do not cover crude oil delivered to the European Union by pipeline - including the Friendship I and II (Druzhba) pipelines.

In 2021 crude oil export revenues accounted for 22% of the total value of the Russian Federation's exports, many times more than those of any other product category.

Annex XXV to the Regulation lists two categories of goods covered by the sanctions according to the Combined Nomenclature:

  • CN 2709 00 - Petroleum oils and oils obtained from bituminous minerals, crude;
  • CN 2710 - Petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70 % or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils.

On 5 December 2022 the ban on importing into the European Union the commodities covered by CN code 2709 enters into force, while on 5 February 2023 the transition period expires, which was introduced to allow importers to make a change in sources of supply for the products covered by CN code 2710.

The sanctions being introduced therefore cover neither natural gas nor liquefied propane-butane gas. Both of these groups fall under CN code 2711 - Petroleum gases and other gaseous hydrocarbons.

As of today (30 November 2022), no common European legislative proposal has been presented concerning restrictive measures targeting imports of gaseous hydrocarbons from Russia.