On 23 June 2023, the EU adopted its latest round of sanctions, the 11^th since February 2022 and the outbreak of the war against Ukraine. With each successive round of sanctions, the EU tightened its restrictions against Russia, with the aim of imposing an outright economic ban against the country and undermining its war efforts.

At the heart of the latest sanctions package is a new anti-circumvention tool, which, according to the European Commission is an exceptional measure of last resort that “will allow the EU to restrict the sale, supply, transfer or export of specified sanctions goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention”.

While the Council has not yet designated the third countries and products concerned, merely introducing the possibility of doing so with this new tool, the European Commission has published two separate lists of products in the wake of the 11^th sanctions package to support due diligence and effective compliance by exporters and targeted anti-circumvention actions by customs and enforcement agencies of third countries determined to prevent circumvention through their territories.

In particular, the Commission published a list of industrial goods subject to restrictive measures for which anomalous trade flows via third countries to Russia have been detected. The goods targeted mainly fall under Chapters 28 (Chemicals), 84 (Machinery), 85 (Electronics), 89 (Maritime) and 90 (Optics and instruments).

The second list, prepared in coordination with the United States, the United Kingdom and Japan, identifies the dual-use goods and advanced technology items that are used in Russian military systems found on the battlefield in Ukraine or that are critical for Russian military systems. The list of High Priority Battlefield Items is divided in four Tiers, covering (i) integrated circuits (Chapter 85), (ii) electronics items (Chapter 85), (iii) electronics components (Chapters 84, 85, 88, 90), (iv) manufacturing equipment (Chapters 84, 85, 90).

The two lists can be downloaded here.

We have provided a further breakdown of the 11th sanctions package and this can be reviewed at our Trade Compliance Resource Hub.