EU's fifth sanctions package both expands the scope of previous sanctions and imposes new types of restrictions on trade with Russia and Russians. A general comment to the new sanctions, in particular the new lists, is that whereas it has previously been rather evident for commercial players which lists to check to verify whether their particular goods or services are subject to any restrictions as to trade with Russia or Russians, it is increasingly challenging to maneuver through the landscape in search of types of goods and services, as several lists may be of relevance.
The dedicated advanced technologies list contained in Annex VII has been updated with a new "miscellaneous" category, in which you will find certain oil and gas exploration and production products, quantum computers, manufacturing equipment, energetic materials etc. It is generally prohibited to sell, export, provide services etc. related to these goods and technologies to Russia or Russians.
The prohibitions on sale and export of and provision of services in relation to etc. goods and technology and related services suited for oil refining have been expanded to also include gas liquefaction and the list in Annex X has been updated with new items.
The prohibitions on sale and export of and provision of services in relation to etc. goods and technology and related services suited for aviation have been expanded to also include jet fuel and fuel additives and Annex XX has been added.
Further prohibitions on sale and export of and provision services in relation to etc. are imposed on certain goods and technology that could contribute in particular to the enhancement of Russia's industrial capacities, as listed in a new Annex XXIII. The list consists of a vast mixture of products, for instance certain flowers, wood, paper products, fabrics, bricks, glass, steel, various metals products, machines and vehicles. Certain exemptions apply, and the prohibition does not apply to the execution until 10 July 2022 of contracts concluded before 9 April 2022.
The EU has further targeted the Russian economy by imposing purchase and import restrictions on certain Russian goods, and provision of services in relation to such goods.
A new Annex XXI lists a variety of goods, and includes e.g. certain fertilizers, wood, alcoholic beverages, cement, concrete, caviar, cruise ships and other specified vessels, etc. These are categorized as goods that generate significant revenues for Russia. Certain exemptions apply to the prohibition, and the prohibition does not apply to the execution until 10 July 2022of contracts concluded before 9 April 2022.
The same type of restriction is imposed on coal and other solid fossil fuels, as listed in a new Annex XXII. The prohibition does not apply to the execution until 10 July 2022 of contracts concluded before 9 April 2022.
As from 16 April 2022, it will be prohibited to provide port access to Russian flagged vessels, and vessels that have changed from a Russian flag or registration after 24 February 2022, to any port within the EU. For this purpose, the regulations define "vessel", and allows a number of exemptions, e.g. for import/purchase of oil or gas, and for coal and other fossil fuels until the above mentioned prohibition on these enters fully into force on 10 August 2022.
As from 16 April 2022, it is also prohibited for Russian transport undertakings to transport goods by road within the EU. A similar yet not identical range of exemptions apply as for vessels.