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06 October 2022

Russia Sanctions: 8th sanctions package

Get an overview of the changes introduced by the 8th sanctions package that your business needs to consider.

Additional listings: These target those involved in Russia's occupation. It also includes individuals and entities working in or for the defence sector. The EU also continues to target actors who spread disinformation about the war. Thirty additional individuals and seven entities have been sanctioned. See "newly listed persons".

New export restrictions:

  • The list of controlled items which might contribute to Russia's military and technological enhancement or the development of its defence and security sector has been expanded (see "new military and technology enhancement products"). This includes nine customs codes classifying electronic components found in Russian weapons. Twenty-two additional chemicals have been added to the list of controlled substances, as well as firearms and other goods that could be used for capital punishment or torture, as set out under the EU Anti-torture Regulation 2019/125.
  • New restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector have been introduced (see Annex "Aviation").
  • Coal exports will be banned subject to a three-month wind-down period of existing contracts signed before the export ban was adopted (see "Annex Article 3k" with additional products in bold).

New import restrictions:

These include a ban on the import of Russian:

  • finished and semi-finished steel products (see "new iron and steel products"). A three-month wind-down period is envisaged to allow for the execution of contracts signed before the import ban on semi-finished steel products was adopted. For some semi-finished steel products with strict technical requirements for further processing by the EU steel industry (two products), the full ban will be phased in after a transition period of up to two years,


  • machinery and appliances;
  • plastics, paper and wood pulp;
  • vehicles, textiles, footwear, leather, ceramics, certain chemical products; and
  • non-gold jewellery.

Implementing the G7 oil price cap: While the EU's ban on importing Russian seaborne crude oil fully remains, the price cap, once implemented, would allow European operators to undertake and support the transport of Russian oil to third countries, provided its price remains under a pre-set "cap".

Restrictions on state-owned enterprises:

  • EU nationals banned from holding posts in the governing bodies of certain state-owned enterprises.
  • It also bans all transactions with the Russian Maritime Register (including its majority owned or directed subsidiaries), adding it to the list of state-owned enterprises which are subject to a transaction ban.

Financial, IT consultancy and other business services:

  • The existing prohibitions on crypto assets have been tightened by banning all crypto-asset wallets, accounts or custody services, irrespective of the amount of the wallet (previously up to EUR 10,000 was allowed).
  • The package widens the scope of services that can no longer be provided to the government of Russia or legal persons established in Russia: these now include IT consultancy, legal advisory, architecture and engineering services.

Deterring sanctions circumvention: The EU has introduced a new listing criterion, which will allow it to sanction persons who facilitate the infringements of the prohibition against circumvention of sanctions. This includes circumvention by EU citizens

Extension of restrictions to the oblasts of Kherson and Zaporizhzhia: The geographical scope of the restrictive measures in response to the recognition of the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas has been extended to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kherson.


author: Christoph Haid



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