ECSA C-12526 For information |ECSA SPC/SAC| New EU sanctions against Russia: restrictions on energy sector, steel and iron, luxury goods

SİRKÜLER NO: 6.12 / 173-129 = 21/03/2022

Konu: ECSA C-12526 For information |ECSA SPC/SAC| New EU sanctions against Russia: restrictions on energy sector, steel and iron, luxury goods Hk.


Üyesi bulunduğumuz FONASBA' dan 18.03.2022 tarihinde almış olduğumuz e- posta mesajı aşağıdaki gibidir.


Dear All,

FONASBA participates in an international industry taskforce on Ukraine coordinated by the International Chamber of Shipping and, similar to the group on COVID, comprises shipowner associations, P&I Clubs, classification societies, crewing and manning agents etc. Through that group we have just received copy of a summary of the latest EU sanctions, originally issued by ECSA to its members on Tuesday 15th. Further information on certain of the sanctions can be accessed via the embedded links.


The summary may prove useful in understanding the current EU sanctions regime.

To        ECSA - Committee Shipping Policy

ECSA - Committee Social Affairs

ECSA - National Associations

ECSA - Secretariat


Ref.      ECSA C-12526  15/03/2022


For information |ECSA SPC/SAC| New EU sanctions against Russia: restrictions on energy sector, steel and iron, luxury goods

Dear Members,

As announced by Commission President Von der Leyen after the informal Summit on Friday, the EU adopted today additional sanctions against Russia, referred to as the “fourth package”. The Secretariat’s preliminary summary of the measures can be found below.

The text of the new restrictive measure includes the following elements: 

·        Further restrictions on the Russian energy sector (link, new articles 2.7/2.7a)

First of all, the energy sector is defined as “(i) exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification; (ii) the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas; or (iii) the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production” (with the exclusion of civil nuclear energy).

The sale, supply, transfer or export of goods and technology including the provision of technical and financial assistance related to the energy sector is prohibited. However, the “transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into the Union” is explicitly exempted (new article 3.3(a)).

Investments in the Russian energy sector (including participations, loans, credit and any financial assistance) are prohibited (new article 3a), with the caveat that exemptions might be granted for the sake of security of supply (art. 3a.2(a)).

Furthermore, new Article 3 and new Annex II to today’s regulation (here) introduced a number of additional annexes to the Regulation, all covered by a ban on sales, supply, transfer or export including the provisions of financial and technical assistance. These include:

·        Import ban on steel and iron (new article 3g)

New annex XVII (page 8) includes all steel and iron products covered by the import ban. In particular, import, purchase and transport activities are covered for products originating in Russia or having been exported from Russia.

Importantly, certain exemptions are provided for import contracts (new article 3g.2) concluded before 16 March. Our understanding from new article 3 is that steel and iron products are also covered by an export ban (insofar as Annex XVII is part of Annex to the Regulation) but the Secretariat will look for further clarification.

·         Export ban on luxury good (new article 3h)

In addition, the sanctions also target the export to Russia of luxury goods (new annex XVIII, page 17 here), banning i.a. the export of:

o    Cruise ships, excursion boats and similar vessels principally designed for the transport of persons; ferry-boats of all kinds (TARIC code 8901 10 00)

o    Other vessels for the transport of goods and other vessels for the transport of both persons and goods (TARIC code 8901 90 00) – the Secretariat is looking into the scope of this item

o    Yachts and other vessels for pleasure or sports (…) (TARIC code 8903 00 00)

·         Ban on transaction with all state own enterprises (new article 5aa and related annex XIX)

The text prohibits any transactions with state-owned or controlled entities (as defined in the article) excluding:

o    Transactions which are strictly necessary for the purchase, import or transport of fossil fuels, in particular coal, oil and natural gas, as well as titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the Union;

o    Contracts concluded before 16 March and only until May 2022

·         Ban on the provision of export credit services

As of 15 April 2022, it is prohibited to “provide credit rating services to any Russian national or natural person residing in Russia or any legal person, entity or body established in Russia”.

·         Extension of ban on export of dual-good technology

Annex IV to the Regulation (page 6), which includes persons and entities covered by the ban on dual-good technology, is further extended (to cover i.a. a number of shipbuilding companies and shipyards).

The list of sanctioned individuals and the list of entities subject to asset freeze has also been further amended and can be found here. With regard specifically to the list of entities, two state-owned shipyards (JSC Zelenodolsk Shipyard and JSC United Shipbuilding Corporation) were added.

The related Council Decisions implementing the above can be found here and here.

Separately, the Commission was given the green light to join, on behalf of the EU, a statement at WTO level condemning Russia’s aggression and putting on the table possible measures in support of Ukraine and against Russia and Belarus. The text of the statement is not yet available.

For ease of reference, the Commission and the Council’s press releases on the package can be found here and here.

The Secretariat is analysing the text in further detail and remains at your disposal should you have any questions.


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