Sanctions imposed

Council Regulation (EU) 833/2014

Consolidated text of sanctions imposed on Russia in connection with the war in Ukraine (as of 12.04.2022) concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Regulation (EC) No 765/2006

Consolidated text of the sanctions imposed on Belarus in connection with the war in Ukraine (as of 12.04.2022) concerning restrictive measures in view of the situation in Belarus and Belarus’ participation in Russia’s aggression against Ukraine

This is a simplified and generalised summary,
which is not legally binding and does not replace legislation.

  • It is prohibited to import goods originating in or exported from Russia, the sale of which generates significant revenues for Russia, such as timber and timber products, furniture, fertilisers, etc. The full list of commodity codes and names can be found in Annex XXI to Council Regulation (EU) 2022/576. The prohibition shall not apply to contracts concluded before 9 April 2022 or ancillary contracts necessary for the execution of such contracts until 10 July 2022.
  • Direct or indirect imports of iron and steel products from Russia are prohibited. The transport of these goods and other technical or financial services are also prohibited. In certain cases, if a contract has been concluded before the imposition of the sanction (before 16 March 2022), it is permitted to import goods on the basis of the contract until 17 June 2022. Commodity codes and names can be found in Council Regulation (EU) 2022/428, Council Decision (CFSP) 2022/430 and Commission Implementing Regulation (EU) 2022/434.
  • Imports of goods from Russia are prohibited if the true origin of these goods is Donetsk or Luhansk Oblast
  • Sanctions include certain persons and citizens of Russia and their assets (details of the sanctions are available in the Official Journal of the European Union here and here).
  • Russia is subject to export-oriented sanctions concerning dual-use items (approximately 600-700 CN). This includes restrictions on export to Russia of various petroleum extraction and exploration goods (pipes, drilling equipment, pumps, etc.). All goods in Chapter 88 of the CN (aviation) are prohibited.

    It is prohibited to sell, supply, transfer or export, directly or indirectly, maritime navigation goods and technology originating in or outside the Union to any natural or legal person, entity or body in Russia or for use in Russia or for the placing on board of a vessel flying the Russian flag.

    CN headings 8526, 8529, 9014

    Heading 8526 - Radar apparatus, radio navigational aid apparatus and radio remote control apparatus. This includes, inter alia, radar navigation equipment for ships or aircraft (either for assembly on ships, aircraft, etc.), including port radar equipment for buoys, identification devices for beacons, etc.
    Range and direction finding radar apparatus for naval or anti-aircraft guns.
    Radio apparatus for the remote control of ships, pilotless aircraft, rockets, missiles, toys, model ships or aircraft, etc.

    Heading 8529 - Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528.

    Heading 9014 - Direction finding compasses; other navigational instruments and appliances. These include:
    A) Instruments for the determination of a ship’s position, such as sextants, octants, azimuths, etc.
    B) Other special marine or river navigational instruments such as automatic pilots (Gyro pilot); course recording apparatus; inclinometers, logs, sounding leads, echo sounding instruments; ultrasonic sounding or detecting equipment. Parts of this heading are to be classified in the same heading.

    • Exports of luxury goods to Russia have been banned. It is prohibited to sell, supply, transfer or export, directly or indirectly, luxury goods to any natural or legal person, entity or body in Russia or for use in Russia. The prohibition applies to luxury goods insofar as their value exceeds EUR 300 per item.  Commodity codes and names can be found in Council Decision (CFSP) 2022/430.
    • Certain goods originating in and coming from Belarus are prohibited — in general terms, the transport (import, export, transit) of fertilisers, tobacco-related equipment/devices (including filters, paper, etc.) and petroleum products is prohibited. Imports of wood, cement, iron, steel and rubber products are prohibited, but the Regulation also contains specifications. In certain cases, if a contract was concluded before the imposition of the sanction, it is permitted to import goods on the basis of the contract until 4 June 2022.
      Please refer to Regulation 2022/355 for details.
    • It is prohibited to move dual-use goods to Belarus under export or other customs procedures.
    • Goods shipped from Ukraine’s Donetsk and Luhansk Oblasts are prohibited and it is prohibited to send goods to Donetsk and Luhansk Oblasts. Sanctions are imposed on all goods.

    Sanctions

    Please note that if a means of transport arrives in Estonia or leaves Estonia by sea, the obligation to carry out customs formalities applies to goods entering or leaving Estonia. In addition, in order to ensure the implementation of sanctions imposed by the EU in connection with the Russian military aggression in Ukraine, customs will carry out controls on goods during loading, unloading and transhipment. If the goods are not unloaded during a port call, the customs authorities have the right to verify the purpose of the transport of the goods on board and, if necessary, to require the goods to be unloaded for the purpose of carrying out an inspection. In accordance with Article 127(2) of the Union Customs Code, an entry summary declaration must also be lodged for means of transport and goods passing through territorial waters in case of a stop in the customs territory (the requirement does not apply upon entry into territorial waters for the purpose of providing supplies only).

    The purpose of the inspections is to prevent any movement of sanctioned goods through the customs territory of the European Union.

    For further questions on the application, validity and exact content of sanctions, please contact the Strategic Goods Commission (stratkom@vm.ee).
     

    If the goods are subject to inspection, please provide the following information:

    • all documents
    • commodity code and description
    • consignee/consignor
    • technical documentation, description and specification of goods
    • confirmation from the end-user that he is the final recipient of the goods and for which the product is used (e.g. an intermediary or customs warehouse is not the final recipient)
    • in the case of EU goods, a confirmation from the manufacturer’s Member State that they are aware that the goods are allowed to be shipped to Russia. The confirmation must be provided by:
      • the competent authority which issues the authorisations for strategic goods, and
      • the manufacturer stating that he or she is aware that the goods are not dual-use goods and he or she is aware that the final consignee of the goods is in Russia or Belarus.

     In addition, please note that the competent authority for imposing sanctions is the Ministry of Foreign Affairs, which makes it difficult to obtain the necessary answers on weekends. Therefore, we recommend not to plan export of goods for the weekend.

    When the exporter of goods is a person of another Member State, the relevant authority of the Member State concerned will also be contacted regarding the technical documentation and specifications of the goods, which means that it takes a considerable amount of time to check such exports. Such goods will not be allowed to leave the customs office of exit until it is established that the goods are not subject to sanctions.

    Please take into account that customs clearance and consultation takes more time than usual. 
    If you need consultation, please note that every detail is important and can influence and change the content of the consultation.

    Ukrainian topics

    Oral declaration for export is not allowed in cases where the goods to be declared are subject to prohibitions or restrictions or where there are specific requirements for the declaration of goods (e.g. licences). Examples include the declaration of fuel, for which a usual customs declaration has to be lodged.

    In the case of humanitarian aid consignments dispatched from third countries (including consignments in temporary storage, customs warehouses, free zones), the following should be taken into account:

    • If the aid consignments are intended for delivery to the territory of Ukraine, they can be moved to the EU under the oral declaration for temporary admission procedure (Article 136(1)(I) of the Union Customs Code delegated regulation). A supporting document for an oral customs declaration must be presented to customs authorities for the purpose of placing the goods under temporary admission. The re-export of goods temporarily admitted into the EU takes place orally in the country where the goods leave for Ukraine. Such movement of goods is exempt from guarantee requirement (under Article 81(a) of the the Union Customs Code delegated regulation). Write-off from stock records must be recorded using the above (import) supporting document form.  
    • As an alternative to the above, the usual declaration for re-export and transit of goods is possible if the person does not have clear information that the goods will be delivered to Ukraine and that the exit of the goods from the EU is certain.  
    • If aid consignments from third countries are for use in a Member State at the EU border, i.e. the goods do not leave the EU, they are declared orally on entry into the EU as non-commercial consignments in accordance with Article 135(1)(a) of the Union Customs Code delegated regulation and are delivered to the place of destination. This is the case even when the person who declares is not a private person but, for example, an aid organisation which dispatches goods from a third country and declares it in Estonia.
      N.B. The aid consignment must meet the conditions for exemption from customs duty. In order to apply for exemption from customs duty, please send a written application and all supporting documents to emta@emta.ee. The duty exemption will be recorded in writing by customs authorities.
      N.B. This is a temporary solution until the EU decision on the customs duty exemption.

    Aid organisations as well as other companies that have organised donations (e.g. diapers, clothes, blankets, etc.) to assist the Ukrainian people are exempted from declaring goods for export by means of a written export declaration. The goods are deemed to be declared orally in the Member State where the goods leave the EU for Ukraine under Article 137(1)(a) of the Union Customs Code delegated regulation.

    The Polish customs authorities have announced that consignments must be declared for export in writing. The commodity codes 9919000050 (goods for charitable or philanthropic organisations) or 9919000060 (goods for the benefit of disaster victims) may be used on the export declaration of goods and the declaration must be accompanied by a list of goods allowing the identification of goods if necessary.

    EU goods intended for use in the EU (e.g. at the Polish border) are not subject to customs procedures.

    The Polish customs authorities have forwarded a recommendation to coordinate the delivery of humanitarian aid through the Ministry of Foreign Affairs.

    Information on coordination can be found on the English-language website of the Polish Government. On this page you will find an application form and information for anyone who wishes to provide aid to Ukraine. In this case, the coordination of customs formalities (export) will take place within this network

    Persons who wish to provide assistance without central coordination (i.e. not through the Ministry of Foreign Affairs) must take into account the following customs formalities:

    UNION GOODS
    1. Oral declaration for export if the value of the goods does not exceed 1000 euros and the goods must be presented at the customs office of exit. No electronic or paper-based declaration is required.
    2. Electronic customs declaration to be lodged at the customs office of export (i.e. at the customs office in Estonia). The declaration may contain a single goods item with a commodity code of the goods with the highest value.
    3. Simplified customs procedure on the basis of a form available on the English-language website of the Polish Government. NB! The export based on the form can take place only through the Dorohusk and Korczowa border crossing points. The border crossing point will be immediately informed of the completion of the form. When using this option, there are also specific requirements for the labelling of the means of transport. The use of the form is permitted regardless of whether the transport starts from Poland or from another Member States. If a person can not sign the form electronically, he or she will be asked to contact the charities or authorities in Poland, which can complete the form on his or her behalf.
    NON-UNION GOODS

    The Polish customs authorities expect non-Union goods to arrive at the border under the transit (T1) procedure. However, if necessary, the simplified temporary admission procedure initiated in another Member State will also be accepted and the goods will be able to leave Poland for Ukraine. For customs operations, it is recommended to contact the nearest customs office in advance.

    NB! The simplified form for Union goods does not apply to non-Union goods.

    Under Article 251 of the Union Customs Code, as a general rule, goods may remain under the temporary admission procedure for a maximum period of 24 months (special cases are set out in Chapter 4 of the Commission Delegated Regulation (EU) 2015/2446 in Section 1 “Temporary admission”). This means that goods may be placed under the temporary admission procedure for the same purpose and under the responsibility of the same authorisation holder for a maximum period of 24 months. This is also the case where the procedure was discharged by placing the goods under another special procedure and the temporary admission procedure was subsequently applied again.

    Where, in exceptional circumstances, the authorised use cannot be achieved within the period laid down, the customs authorities may grant an extension, of reasonable duration of that period, upon justified application by the holder of the authorisation. 

    Goods may be placed under the temporary admission procedure for a period of ten years. This means that goods may remain under the temporary admission procedure for up to 10 years, but not for the same purpose or under the responsibility of the same authorisation holder.

    Live animals, food products, goods subject to veterinary or phytosanitary control, feed and products of animal origin must be certified by the country of origin and are subject to controls in accordance with Ukrainian legislation.

    The original certificates of the countries of origin are checked at the border inspection posts of Ukraine, together with the transport documents.

    In order to speed up customs formalities at the border inspection posts in Ukraine, we kindly ask all exporters of goods subject to plant health and veterinary checks to apply for the necessary certificates from the Agriculture and Food Board and submit the necessary original certificates with transport documents at the Ukrainian border.

    Export requirements and contact details can be found on the website of the Agriculture and Food Board pta.agri.ee.

    1. .Are there only descriptions of the dual-use goods but no commodity codes?  
    The lists of dual-use goods are without commodity codes. The lists contain descriptions and technical specifications of goods. Parameters can be found in the specifications of goods to check whether the goods are on the list of dual-use goods. The commodity code can be used to find initial information from the Estonian Master Tariff System (EMTS). It is indicated next to commodity codes in the EMTS, whether such a commodity code may also be included in the list of dual-use goods and may therefore require authorisation from the Strategic Goods Commission

    2. How to search for sanctions in the EMTS?
    Please check the application of sanctions from the EMTS. The EMTS also publishes information on whether a specific authorisation is required for the clearance of goods.

    3.Can timber/wood products (chapter 44) be imported from Russia?
    Imports of timber products from Russia are currently not prohibited. However, sanctions have been applied to Belarusian timber and timber coming from Belarus.

    4. When goods (metal) coming from Kazakhstan transit through Russia, can such goods be brought into the EU?
    There are no sanctions imposed on Kazakh goods, but upon their entry into the EU, a document certifying the Kazakh origin must be presented to customs authorities. 

    5. If the time limit for temporary storage is about to expire but the goods cannot be delivered to the destination originally planned due to military activities, what should be done? 
    If the time limit for temporary storage is about to expire but the goods cannot be delivered to the destination originally planned due to military activities, the goods must be placed under a customs warehousing procedure or another customs procedure. The UCC does not provide for an extension of the time limit for temporary storage.

    6. How do the different sanctions affect customs clearance?
    The declarant must verify that the goods indicated in customs documents or customs declarations relating to entry/exit are not subject to sanctions. This means that already before customs operations are carried out, it is necessary to check that the export or import of these goods is not prohibited under the EU legislation. Economic operators must also take into account that in addition to goods, sanctions are also imposed on certain individuals and companies, so persons involved in supply chains have a duty of care to verify that the import/export/transit of goods or related transactions/services do not infringe sanctions imposed by the European Union and do not make assets or economic resources directly or indirectly available to listed persons (e.g. payments to a company whose direct beneficiary is a listed person but also situations where an intermediary company is controlled by that person). More detailed instructions for checking financial links

    7. Do the import or export bans also apply to packaging and containers? 
    Prohibitions apply to the goods declared. If the declared goods, which are not subject to sanctions, are packaged with material subject to sanctions, customs clearance of the goods is permitted. If packaging is to be exported/imported separately, it is treated as goods and, in case of being subject to sanctions, import/export is prohibited.

    8. How to deal with non-EU goods in temporary storage destined for the conflict zone or destined to Russia/Belarus but the goods are subject to sanctions?
    It is not possible to extend the time limit for temporary storage of goods and the goods must be placed under customs warehousing or another customs procedure. The time limit for temporary storage will not be extended. In cases where a customs debt may be incurred (e.g. it has become evident that the time limit has expired), terminal keepers must inform the customs authority that issued the authorisation in order to find a solution to the situation.

    9. For how long period is it permitted to place horses rescued from Ukraine on temporary admission?  
    For horses, temporary admission with total relief from customs duty is possible for min 12 months (Articles 223 and 237 of the Commission Delegated Regulation (EU) 2015/2446; customs declaration procedure 53 additional code D08), which can be extended by a maximum of 24 months, but in the context of the war in Ukraine, there is a general approach that the customs authorities may extend the temporary admission of horses for a total of up to 10 years.

    10. Do export sanctions apply to goods that have been under special procedure? 
    In the question of sanctions, re-export is treated in the same way as export. For example, it must be checked whether the goods that have been under a temporary admission procedure and are to be re-exported in order to discharge the procedure are subject to sanctions. Therefore, at the end of temporary admission, another customs-approved treatment or use (release for free circulation, customs warehousing, destruction) should be chosen.

    11. How to assign units to luxury goods? 
    The quantity of units of goods is the quantity indicated on the export declaration on the basis of a supplementary unit (1802000000 or 6/2 or SAD field 41). 
    If there is no supplementary unit for the goods under the EMTS, the number of packages (1806004000 or 6/10 or SAD field 31) must be used to determine the quantity of the units of goods.

    If the number of packages must be  indicated, the number of packages immediately surrounding the goods, i.e. the number of packages for retail sale, must be indicated.  
    If the goods are unpackaged, the number of packages shall be the number of goods.

    Examples
    • Cardboard box with 6 bottles of wine if it is a retail package
    • Bottle of wine if it is intended for sale as a separate bottle

    Last updated: 18.05.2022

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