On 23 June 2023, the EU published its latest sanctions package, dubbed the “11th sanctions package”. At the heart of this latest package is the attempt to target efforts to circumvent the existing sanctions measures, in particular the G7 Price Cap initiative relating to Russian oil and petroleum products. Many questions have already been raised in relation to the interpretation of certain provisions, in particular, the new Articles 3eb and 3ec which empower EU Member State authorities to refuse vessels’ access to ports and locks in certain instances. The EU Commission has yet to release guidance or FAQs on these latest measures but it is hoped that Articles 3eb and 3ec will feature heavily in any such guidance.
It should also be noted that the lists of restricted goods have been reformulated and widened to some extent by removing CN Code references to specific goods at a 6 to 8 digit level, and consolidating some of them to a 4 digit CN Code level. In other words, all goods under that 4 digit CN Code heading would now be caught by the relevant restrictions. It is therefore crucial for market participants to revisit their sanctions checks to ensure that the new lists do not impact existing (or future) trade.
We have provided a further breakdown of the 11th sanctions package and this can be reviewed at our Trade Compliance Resource Hub.