Customs clearance in the context of the war in Ukraine

The European Union adopts the 19th package of sanctions

The EU adopted the 19th package of sanctions aimed at strengthening pressure on Russia and preventing the financing of its war machine.

Important changes and additions

• A ban on the purchase, import or transfer to the EU of liquefied natural gas (LNG) originating in or exported from Russia will enter into force within 6 months for short-term contracts and from 1 January 2027 for long-term contracts.
• The ban on acyclic hydrocarbons will be extended by removing the existing exemption for commodity code 29011000. The transitional period is 3 months.
• 117 vessels are added to the list of vessels subject to sanctions and 4 vessels are removed from the list.
• The existing transaction ban on Rosneft and Gazprom Neft is tightened and the exemptions for transactions in gas, metals, oil and energy projects are removed.
• 45 entities will be added to the list of military end-users and entities involved in sanctions circumvention, including from Russia, China, Hong Kong, India and Thailand.
• Additional goods contributing to Russia’s military development or contributing to Russia’s industrial capacity will be added to the export ban list.
• Measures adopted with the package also prohibit the provision of services related to tourism activities in Russia.

Detailed information on the new sanctions can be found in the legislation.
In order to give effect to the new restrictions, the Council adopted Regulation (EU) 2025/2033.

The amendments will enter into force on 24 October 2025.

The European Union adopts the 18th package of sanctions

The Council of the European Union adopted the 18th package of economic and individual restrictive measures, which will severely impact Russia’s energy, banking and military sectors, as well as trade with the European Union, and will ensure accountability for Russia’s continued war of aggression against Ukraine. Furthermore, the Council complemented the package by agreeing on further measures on Belarus.

Important changes and additions

Energy

• With the 18th package, the European Union is curtailing Russia’s energy revenues through a number of different measures. The European Union is lowering the price cap for crude oil from USD 60 to USD 47.6 per barrel.
• An additional 105 vessels will be subject to a port access ban and a ban on the provision of a broad range of services related to maritime transport.
• Furthermore, the EU is introducing an import ban on refined petroleum products made from Russian crude oil and coming from any third country – with the exception of Canada, Norway, Switzerland, the United Kingdom and the United States.

Military industry

• 26 new entities will be subject to tighter export restrictions concerning dual-use goods and technologies, including those that could contribute to the technological enhancement of Russia’s defence and security sector. Eleven of these entities are located in third countries other than Russia (seven in China and Hong Kong, and four in Türkiye).
• In addition, the European Union agreed on additional export bans worth over 2.5 billion euros.

Detailed and complete information on the new sanctions can be found in legal acts.

To give effect to the new restrictions on Russia, the Council of the European Union adopted:

• Council Regulation (EU) 2025/1494.

Legislation applicable to Belarus:

• Council Regulation (EU) 2025/1472.

The amendments enter into force on 20 July 2025.

On 20 May 2025, EU adopted the 17th package of sanctions

Important changes:

• 189 additional vessels, mainly oil tankers of the “shadow fleet”, were added to the list of sanctioned vessels.
• 31 entities were added to the list of military end-users and companies involved in circumvention of sanctions. These include 18 companies from Russia and 13 from third countries (six from Türkiye, three from Vietnam, two from the United Arab Emirates, one from Serbia and one from Uzbekistan).
• 11 new commodity codes were added to the list of goods supporting Russia’s military and technological capabilities or the development of its defence and security sector. These include chemical compounds (e.g. chlorates, boron), metal powders (e.g. magnesium and aluminium powders), precision bearings and screws, seals and measuring devices

Detailed information on the new sanctions can be found in the legislation.

In order to give effect to the new restrictions, the Council adopted

• Decision (CFSP) 2025/931

• Regulation (EU) 2025/932

The new restrictions entered into force on 21.05.2025.

On 16 December 2024, the European Union adopted the 15th sanctions package

Important changes

• 52 ships were added to the ship sanctions list.
• The list of companies linked to military end-users and the circumvention of sanctions (Annex IV - companies subject to stricter export restrictions) will increase by 32 companies (mainly companies from Russia, but also Serbia, Iran, Hong Kong, China, India, and United Arab Emirates).

Detailed information about the new sanctions can be found in the legislation. To enforce the new restrictions, the council passed

• the Decision (CFSP) 2024/3187

• the Regulation (EU) 2024/3192

The new restrictions came into effect on 17 December 2024.

On 24 June 2024, the European Union adopted the 14th sanctions package

The European Union agreed to tighten sanctions against Russia

The Council of the European Union adopted the 14th package of sanctions expanding the scope of sanctions against Russia. Among other measures, restrictions were imposed on Russian liquefied natural gas (LNG), ships carrying Russian oil and other goods, and export bans were extended to goods used in the military industry. The due diligence of the European Union companies and their subsidiaries are strengthened and a number of key persons and companies are added to the sanctions list.

Brief overview of measures added with the 14th sanctions package

Most important import bans

• Further restrictions were introduced on the import of helium (Article 3i, Annex XXI).
• Import restrictions are introduced on Russian LNG through Union LNG terminals that are not connected to the interconnected natural gas system.
• The import ban on diamonds was changed (Article 3p).
• A ban on the purchase, sale, transfer of stolen Ukrainian cultural values was added (Article 3v).
• Customs operations of the dark fleet listed in the Annex to the Regulation and the entry into and provision of services to the ports of the Member States were prohibited (Article 3s, Annex XLII).

Most important export bans

• New export bans were imposed on manganese ores and compounds of rare-earths, plastics, electrical equipment and goods used by Russia in the war in Ukraine, including machine tools and all-terrain vehicles (Article 3k, Annexes XXIII and XXIIIC). More detailed information in the regulation.
  The change covers commodity code groups 28, 29, 38, 39, 84, 85, 81, 86, 87, 96, which are subject to different transition periods.

Services

• Transshipment and other services that enable the export of Russian LNG will be prohibited (Article 3r, transition period 9 months).
• Reloading services in the territory of the Union for the purposes of transshipment operations where such services are used to transship Russian LNG, except in the case of such transshipments to Member States, are prohibited. That prohibition covers both ship-to-ship transfers and ship-to-shore transfers and re-loading operations. Ancillary services related to such transshipments are also banned.
• New investments to Russian LNG projects are prohibited, including Arctic LNG 2 and Murmansk LNG (Article 3a, Article 3t, transition period 3 months).
• A new ban affects road transport services. Union operators which are owned for 25% or more by a Russian natural or legal person are prohibited from becoming a road transport undertaking or from transporting goods by road in the Union, including in transit. The prohibition does not apply to road transport undertakings owned by dual nationals or Russian nationals having a temporary or permanent residence permit in a Member State. Check your transport service partners.

Expansion of due diligence

• European Union companies must undertake their best efforts to ensure that their subsidiaries in third countries do not violate export bans on sensitive goods (Article 8a).
• Due diligence requirements, including those that provide for the provision of mandatory contractual conditions, were improved to ensure that third country contracting partners of European Union companies do not export battlefield goods to Russia or take intellectual property acquired with them there, the so-called no-Russia clause (Articles 12, 12g, 12ga, 12gb).
• 61 Russian and third-country companies (including third-country companies involved in sanction evasion) will be added to the list of defence industry companies and will be subject to stricter export restrictions.

You can find detailed information on the new sanctions in legislation.

To enforce the new restrictions, the council passed:

• decision (CFSP) 2024/1738

• regulation (EU) 2024/1739 and implementing regulation (EU) 2024/1746

You can read more about the new sanctions in the Council Regulations (EU) 2024/1745 and 2024/1865. To see the Annexes, we recommend that you select the PDF-version.

On 23 February 2024, EU adopted 13th package of sanctions

The Council of the EU adopted the 13th package of sanctions to expand the scope of sanctions against Russia.

Brief overview of MEASURES added with the 13th package

• 27 entities subject to tighter export restrictions are added to the list of natural or legal persons, entities or bodies (Annex IV) referred to in Articles 2(7), 2a(7) and 2b(1) of Council Regulation (EU) No 833/2014. These include 17 entities from Russia, 3 from China, 1 from Turkey, 1 from Thailand, 1 from Kazakhstan, 1 from Serbia, 1 from Hong Kong, 1 from Sri Lanka and 1 from India.
• Additions are made to Annex VII to Council Regulation (EU) No 833/2014, which lists the goods and technology the export of which to Russia or the transit of which via the territory of Russia is prohibited because the goods or technology might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector. In Part B of Annex VII, commodity code “8532 22 – aluminium electrolytic fixed electrical capacitors (excluding power capacitors)” is added.
• Additions are made to Annex XXIII referred to in Article 3k of Council Regulation (EU) No 833/2014, which lists goods subject to an export ban. In addition to the goods with 6-digit codes 8504 32, 8504 33 and 8504 34 already subject to sanctions, the export of all goods falling under the heading 8504 will be banned. A transitional period of 3 months will apply to goods of heading 8504 the export of which was not already prohibited.
• Additions are made to the list of partner countries from which iron and steel are imported (Annex XXXVI referred to in Article 3g(1) of Council Regulation (EU) No 833/2014). The list of partner countries now includes the United Kingdom in addition to Switzerland and Norway. Partner countries have imposed their own restrictive measures on metals from Russia and no evidence of origin must be submitted upon importing iron and steel from these countries.
• Council Regulation (EU) 269/2014: 106 individuals and 88 entities are added to the list of sanctioned persons. Following the adoption of the 13th sanctions package, the list contains 1752 persons and 425 entities (2177 in total).

More information on the additional sanctions can be found in Council Regulation (EU) 2024/745.

On 18 December 2023, the EU adopted the 12th package of sanctions

In view of Russia’s actions destabilising the situation in Ukraine, the Council of the European Union decided to adopt new restrictive measures with which:

• new import bans on the following goods are added:

• diamonds and products containing diamonds (jewellery). Ban on direct import from Russia will enter into force on 1 January 2024; ban on indirect import from third countries, including on processed diamonds, will enter into force on 1 March 2024; import ban on smaller diamonds will enter into force on 1 September 2024.
• LPG – the transition period is 12 months;
• metals (processed aluminium, wires, tubes). The exception is products of iron and steel (including steel plates) which may be imported until 2028 (subject to quotas).

• new export bans are added on goods, which have been used by Russia in its war of aggression against Ukraine, including software, transformers, bearings, machine tools, lithium compounds, converters, construction goods, transport goods, laser technology and drone components;
• the ban on transit through Russia to third countries is extended for certain goods used in the military industry, which are important for the Russian economy;
• it becomes obligatory to include in contracts a clause prohibiting the resale of the most dangerous goods to Russia;
• the oil price cap is enforced: it will be prohibited to sell oil tankers (with certain exceptions), a more accurate overview of the costs related to Russian oil shipments will be required, and an obligation to share the information required for enforcement is added;
• an obligation to notify of the transfer of assets of Russian entities to Russia is added. Applies only to transfers of legal persons owned (25% or more) by Russian persons.
• exemptions from import restrictions are added to facilitate travel between Russia and the EU and the movement of EU citizens between Russia and their home countries:

1. Member States may allow persons crossing the border to carry prohibited goods if it is evident that they are for personal use on the journey;
2. EU citizens residing in Russia may apply for authorisation to enter the EU by car if it is intended for personal use. A Member State is not required to issue such authorisations.

More information on new sanctions can be found in the Council Decision (CFSP) 2023/2874 and Council Regulation (EU) 2023/2878.

Consolidated legislation: Council Decision 2014/512/CFSP (as of 1 October 2023), Council Regulation (EU) No 833/2014 (as of 19 December 2023).

The new restrictions will enter into force on 19 December 2023.

On 23 June 2023, the European Union adopted the 11th package of sanctions

On 25 February 2023, the European Union adopted the 10th package of sanctions

Customs procedures for goods brought into the European Union before sanctions

In order to ensure legal certainty regarding the treatment of imports, the 10th package lays down rules for the release by customs authorities of goods physically located in the Union and already presented to customs authorities in cases where sanctions apply to those goods. This possibility applies regardless of the procedure applied to the goods after presentation to customs (transit, inward processing, release for free circulation, etc.) or the procedural steps and formalities required to release the goods according to the Union Customs Code.

The change concerns Union businesses that brought goods into the Union in good faith at a time when they were not yet subject to any import restrictions, including when their imports were still allowed during the transition period. When declaring such goods, the release of the goods and related payments (prohibition of acquiring the goods!) must be in accordance with the provisions and objectives of the restrictive measures of the Union.

When declaring such goods, additional code Y859 is used and information about the time of presentation of the goods and payment is made available to the customs. If the delivery of goods to the Union was subject to a transition period and contractual derogations, the customs declaration must be accompanied by contracts that must meet the requirements of the legislation (e.g. a contract concluded a certain time before the end of the transition period).

Example

On the basis of Art. 3i of the Regulation 833/14, it was allowed to deliver goods A to the Union until 10.07.22, provided that the contract on the basis of which the goods were brought to the Union was concluded before 10.04.22. The goods reached the Union on 09.06.22 and the contract was concluded on 03.2022. The goods were placed in a customs warehouse and remained there after 10.07.22. Such goods may be declared for the next customs procedure.

One of the restrictive measures introduced was a ban on the entry of vehicles with Belarusian licence plates into the European Union (EU).

It is prohibited to directly or indirectly purchase, import or transfer crude oil and petroleum products listed in Annex XXV if they originate in Russia or are exported from Russia. It is prohibited to directly or indirectly provide technical assistance, brokering services, financing or financial assistance or any other services related to the aforementioned prohibition. A full list of commodity codes and names can be found in Council Regulation (EU) No 833/2014 and its amendments (we recommend using a combination of the consolidated version and the regulations related to the most recently adopted package for searching).

The vast majority of fuel bans are regulated in the articles of Council Regulation (EU) No 833/2014:

• Article 3m, Annex XXV
  crude oil and petroleum products, CN headings 2709 and 2710
• Article 3n
  services related to fuel
• Article 3i, Annex XXI
  coal

Further guidance on import of steel products has been issued (2 Oct 2023) by the European Commission (on the implementation of Article 3g(1)(d) of Council Regulation (EU) 833/2014). Therefore, we are publishing new guidelines.

• If the goods specified in Annex XVII to Council Regulation 833/2014 have been transported into the EU and presented to customs before 30 September 2023, sanctions shall not apply and a declaration shall refer to the code Y859 (Article 12e).
• From 30 September 2023 it is prohibited to transport into the EU iron and steel products produced in a third country incorporating iron and steel inputs originating in Russia. The prohibition applies to iron and steel products listed in Annex XVII to the Regulation (tariff headings 7206 to 7229 and Chapter 73 of the Combined Nomenclature).
• For goods which have entered the EU after 30 September 2023, documentation must be provided to prove the origin of inputs. Declarations must contain a reference to the additional code Y824 (Article 3g). Documents proving the absence of Russian inputs in a product must be presented to customs as customs declaration’s supporting documents certifying the origin of the inputs, including documents proving non-preferential origin. The requirement to submit documents of origin has been made public and applies as of 23 June 2023 from the publication of the XI package.

With regard to the applicable prohibition, as of 30 September 2023, importers of such goods have to submit to the Tax and Customs Board evidence that Russian iron and steel have not been used for the processing of iron and steel products produced in a third country.

To prove the origin of iron and steel, please provide:

• A mill test certificate (MTC) or certificates, if all information cannot be summarised in one single MTC.

The document must contain the following: the name of the country where iron and steel melting took place and a six-digit commodity code, as well as the name of the country and factory where the processing operation (for example rolling, welding, piercing, etc.) was carried out.

• If an MTC has not been issued, the following documents can be used as evidence of the country of origin: invoices, delivery notes, supplier’s declarations, product descriptions.

Documents proving the country of origin must be declared for all import procedures, including inward processing and storage. To declare documents in the import declarations system, the supporting document code Y824 must be used and files uploaded.

Please consult the frequently asked questions on the website of the European Commission as well.

Questions and answers

In accordance with Council Regulations (EU) 833/2014 and 765/2006, it is prohibited to bring (including purchase, deliver, transfer) plywood exported from Russia and/or Belarus or plywood of Russian/Belarusian origin to the EU.

The European Commission has issued a warning, drawing attention to the high risk of circumvention of sanctions in relation to the transport of plywood (CN 4412) to Europe from third countries, including Turkey, Kazakhstan, China. Economic operators delivering plywood originating in a third country to Europe must verify that the imported plywood does not in fact originate in Russia or Belarus, irrespective of the country of dispatch and the corresponding contracts and documents proving the origin. Russian and Belarusian plywood is often shipped to third countries with the aim of hiding its origin.Upon import into Europe, origin is proved by providing false or misleading documents. Goods are delivered to the Union using illogical routes and often goods are processed in a way that is not financially reasonable. The conveyance of such plywood to the EU constitutes a violation of international sanctions which is punishable as a criminal offence and may result in the confiscation of the goods. Offering services, including brokering, logistics support and warehousing, are also considered a violation of sanctions.

Please note that regardless of the country of dispatch or origin, all imports of timber and timber products are subject to increased customs attention, which means that the process of importing timber and timber products is considerably slower than before.During the customs control at the border, the first decision is made on whether the timber or timber products are allowed to enter the EU.

The EU consignee (regardless of the country of destination) has to provide forestry-related documents to customs officials via the person communicating with customs at the border in order to prove that due diligence has been exercised. Forestry-related due diligence obligations are laid down in Regulation (EU) No 995/2010 of the European Parliament and of the Council. Articles 4 and 6(1)(b) of Regulation (EU) No 995/2010 prohibit the placing on the market of illegally harvested timber, which includes timber subject to sanctions (Council Regulation (EU) No 833/2014 imposes sanctions on timber exported from or originating in Russia and Council Regulation (EU) No 765/2006 imposes sanctions on timber exported from or originating in Belarus).

To exercise due diligence, original documents containing the following information must be presented to customs.

1. Export declaration lodged in the country of dispatch.
2. Other customs and transport documents (e.g. invoice of purchase and sale, contract of purchase and sale, transport contracts from place of departure to place of destination, transport vehicle GPS data from transport companies, tachograph data, etc.).
3. Goods description, including the trade name and type of product as well as the common name of tree species and, where applicable, its full scientific name (in a purchase and sale documents or in a contract).
4. Country of harvest (in a concession of harvest).
5. Concession of harvest; neccesary information: quantity, name and address of the supplier to the operator, name and address of the trader to whom the timber and timber products have been supplied, documents or other information indicating compliance of those timber and timber products with the applicable legislation.

All plywood loads that cross the external border and move under the transit procedure to one of the customs offices of destination in Estonia must be directed to the customs terminal (or customs warehouse, if the plywood also needs CE marking) chosen by the customer for a following customs procedures. The goods are cleared for import only in the customs terminal/customs warehouse. Goods presented at the customs office of destination on the means of transport cannot be cleared for free circulation because the goods that are on the means of transport cannot be checked. Please note that if the goods have been brokered, processed, transhipped or stored in Russia, the goods are considered as originating in the Russian Federation. The same applies to the changing of a truck and/or trailer in the Russian Federation.

If necessary, samples and analyses of the goods are taken to identify the geographical area the timber originates in and/or the tree species. Laboratory analyses can be time-consuming and, in order to prevent sanctioned goods from reaching the market, goods are not released from customs supervision until the laboratory results have been received and all relevant documents have been checked. Until the results are available, the goods must be located in a customs terminal or customs warehouse under customs supervision.

Timber and timber products (including plywood) are not recommended to be placed under customs procedure 42 (free circulation with transfer to another Member State), as the procedure remains under supervision until all risks (including VAT risk) are mitigated. This means that the presentation to customs of the documents relating to the end of the transport operation is not sufficient to finish the customs supervision of the goods declared for procedure 42. When transporting goods to another Member State, please use the transit procedure provided for this purpose.

• If the imported goods comply with the rules on preferential origin, a proof of preferential origin (statement on origin or EUR.1 or origin declaration) made out by the exporter of the goods must be submitted to the customs authorities. As regards proof of origin, the ETCB’s website contains a "Table on proof of origin" („Abistav tabel päritolutõendite kohta“).
• If the preference code starts with 1xx or 4xx, the proof of the country of origin of the goods must be based on the EU's non-preferential rules of origin and be accompanied by documents proving the origin of the goods.

Economic operators that are unable to present the necessary documents to customs and prove the non-preferential origin of plywood upon crossing the border are advised not to transport plywood to the EU.

In order for the border crossing and customs clearance to proceed faster, we ask you to submit the necessary documents as supporting documents for the customs declaration at the time of submission of the customs declaration.

It is prohibited to import goods originating in or exported from Russia, the sale of which generates significant revenue for Russia. A full list of commodity codes and names can be found in Council Regulation (EU) No 833/2014 and its amendments (we recommend using a combination of the consolidated version and and the regulations related to the most recently adopted package for searching).

The vast majority of import bans are regulated in the articles of Council Regulation (EU) No 833/2014:

• Article 3g, annex XVII
  iron and steel products
• Article 3i, annex XXI
  goods which generate significant revenue for Russia.
• Article 3o, annex XXVI, XXVII
  precious metals and articles thereof

It is prohibited to import goods from Russia if the real origin of these goods is the Donetsk or Luhansk oblast.