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EU sanctions in response to the situation in Ukraine
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EU sanctions are legally binding on all natural and legal persons in Ireland and the EU. EU Council Regulations have direct effect, and must therefore be complied with in the same way as domestic Irish legislation.
Derogations to EU sanctions are provided for in the legal acts. Individuals and entities may apply under these derogations for authorisation to take actions otherwise prohibited by the sanctions. Requests for authorisations should be made to the relevant competent authority:
Derogations for Russian Flagged Ship: After 16 April 2022, Russian flagged vessels, and vessels re-registered from the Russian flag after 24 February 2022, are banned from accessing EU ports. Derogations are possible in exceptional circumstances. If applying for a derogation for this purpose, please find more information here .
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
On 24 June 2024, the EU adopted a fourteenth package of sanctions against Russia and Belarus.
Council Regulation (EU) 2024/1745 of 24 June 2024 amends Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. The amendments pertaining to transport are as follows.
• provide access to ports, anchorage zones and locks in the territory of the Union, and for such a vessel to access them;
• import into the Union, purchase or transfer such a vessel;
• sell, supply, including charter, or export such a vessel;
• operate or crew such a vessel;
• provide flag registration for the benefit of such a vessel;
• provide financing and financial assistance, including insurance, as well as brokering services, including ship brokering;
• provide technical assistance and other services including bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services to the benefit of such a vessel; and
• engage in ship-to-ship transfers or any other transfer of cargo with, or procure any services from, such a vessel.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
On 23 February 2024, the EU adopted a thirteenth package of sanctions against Russia. The next day, 24 February 2024 would be 2 years since Russia invaded Ukraine.
This package focuses on further limiting Russia's access to military technologies, such as for drones, and on listing additional companies and individuals involved in Russia's war effort.
With this new package the number of listed companies and individuals has reached over 2000.
Council Regulation (EU) 2024/745 comes into effect 24 February 2024.
Council Implementing Regulation (EU) 2024/753 came into effect 23 February 2024
The EU adopted a twelfth package of sanctions against Russia. This package seeks to target high-value sectors of the Russian economy (including, as part of a G7 effort to develop an internationally coordinated diamond ban, a prohibition on the direct or indirect import, purchase or transfer of diamonds from Russia) and make it more difficult to circumvent EU sanctions including those related to the oil import ban and G7+ Coalition price cap.
The following transport measures are included in this package under Council Regulation (EU) 2023/2878 amending Regulation (EU) No 833/2014 :
• Itemised price information for ancillary costs, such as insurance and freight, will be shared upon request throughout the supply chain of Russian oil.
• The Commission and Member States will periodically share information with each other to help further identify vessels and entities of concern carrying out one or more deceptive practices while transporting Russian crude oil and petroleum products.
• The sale of new tanker to third countries will be notified. In the case of sales to Russian persons and entities, or for use in Russia, such sales will be subject to an authorisation. This notification obligation applies to the owner of a tanker who is a national of a Member State, to a natural person residing in a Member State, and to a legal person, entity or body which is established in the EU. The owner, or anyone acting on their behalf, should notify the competent authorities of any such sale concluded since 5 December 2022 and provide all the necessary details.
• An import ban will no longer apply to vehicles (CN code 8703) that have a diplomatic vehicle registration plate and are necessary for the functioning of diplomatic/consular representations/international organisations or for the personal use of their staff and their immediate family members. Furthermore, to facilitate the entry into the Union of EU citizens living in Russia, Member States can authorise the entry of such vehicles provided they are not for sale and are driven for strictly personal use.
Council Regulation (EU) 2023/2878 came into effect on 19 December 2023.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases
The EU adopted an eleventh package of sanctions against Russia. This package of economic and individual restrictive measures intends to strengthen existing EU sanctions and mitigate circumvention.
The following transport measures are included in this package under Council Regulation (EU) 2023/1214 amending Regulation (EU) No 833/2014 :
Council Regulation (EU) 2023/1214 came into effect on 24 June 2023.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
Following the one year anniversary of Russia’s invasion of Ukraine on 24 February, the EU adopted a tenth package of sanctions against Russia. This package:
• imposes further import-export controls and restrictions;
• suspends two additional media outlets;
• restricts the possibility for Russian nationals to hold any position in the governing bodies of owners and operators of critical infrastructures, EU critical infrastructures and critical entities;
• introduces the prohibition to provide gas storage capacity (with the exclusion of the part of LNG facilities) to Russian nationals;
• introduces (i) more detailed reporting obligations on funds and economic resources belonging to listed individuals and entities which have been frozen or were subject to any move shortly before the listing, (ii) new reporting obligation to the Member States and to the Commission on immobilised reserves and assets of the Central Bank of Russia and (iii) new requirement for aircraft operators to notify non-scheduled flights from Russia to the EU to their competent authorities; and
• lists an additional 87 individuals and 34 entities.
Aviation
Council Regulation (EU) 2023/427 amends Regulation (EU) 833/2014 introduces an obligation for aircraft operators to notify non-scheduled flights between Russia and the EU. This applies to those operating directly or via a third country. The notification must be made prior to operation, and at least 48 hours in advance, to the competent authorities of the destination Member State.
The Member State concerned should immediately inform other Member States, the Network Manager and the Commission where it does not clear such flights.
The Regulation notes that this is introduced to avoid circumvention of, and ensure compliance with, the prohibition on any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body from landing in, taking off from, or overflying, the territory of the EU (see 28 February 2022 further below).
Maritime
Council Regulation (EU) 2023/427 also amends Regulation (EU) 833/2014 to provide for certain exemptions for EU operators to provide pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety.
These aviation and maritime measures came into effect on 26 February 2023.
Listed Persons/Entities
In relation to transport, Council Implementing Regulation (EU) 2023/429 amends Regulation (EU) No 269/2014 adding ten Deputy Ministers of the Ministry of Industry and Trade (responsible for areas including aviation technology), an aircraft manufacturer, a ship management company, and a company that maintains Russia’s icebreaker fleet.
These measures came into effect on 25 February 2023.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU with the G7+ Price Cap Coalition adopted the price cap for seaborne Russian petroleum products falling under CN code 2710 which originate in or are exported from Russia. The level of the price cap is introduced under Council Implementing Regulation (EU) 2023/251 amending Council Regulation (EU) No 833/2014 .
The max price levels are as follows:
This price cap will be implemented from 5 February and will be continually monitored and adjusted as appropriate.
There will be a 55-day wind-down period for seaborne Russian petroleum products purchased above the price cap, provided it is loaded onto a vessel at the port of loading prior to 5 February 2023 and unloaded at the final port of destination prior to 1 April 2023. The is set out under Commission Regulation (EU) 2023/250 amending Council Regulation (EU) No 833/2014 .
This follows the 6 October Council Decision (see further below) prohibiting the maritime transport of Russian crude oil (as of 5 December 2022) and petroleum products (as of 5 February 2023) to third countries, and the related provision of technical assistance, brokering services or financing or financial assistance. The Council Decision also contained an exemption for these prohibitions should the oil be purchased below a pre-established price cap.
An "emergency clause" was previously introduced, on 3 December 2022 (see further below), which allows the transport of crude oil and petroleum products beyond the price cap or the provision of technical assistance, brokering services or financing or financial assistance related to the transport necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a ninth package of sanctions against Russia. This package:
Exports
In relation to transport, Council Regulation (EU) 2022/2474 amends Regulation (EU) 833/2014 to expand the export ban to include CN 840710 (spark-ignition reciprocating or rotary internal combustion piston engine, for aircraft) and CN 840910 (parts suitable for use solely or principally with internal combustion piston engine for aircraft, n.e.s.). It also introduces a derogation for certain aviation goods*, which are also widely used in the medical field, to be exported for medical, pharmaceutical and humanitarian purposes.
These measures came into effect on 17 December 2022.
Listed Persons/Entities
In relation to transport, Council Implementing Regulation (EU) 2022/2476 amends Regulation (EU) No 269/2014 adding two aviation products manufacturers, a shipbuilding company, a manufacturer of trucks, and the Russian Navy.
These measures came into effect on 16 December 2022.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The European Council set an oil price cap at USD 60 per barrel, applicable from 5 December 2022. This applies to crude oil, petroleum oils and oils obtained from bituminous minerals (CN code 2709 00) which originate in or are exported from Russia. The price cap is introduced under Commission Implementing Regulation (EU) 2022/2368 amending Council Regulation (EU) No 833/2014 .
This price cap follows the 6 October Council Decision prohibiting the maritime transport of Russian crude oil (as of 5 December 2022) and petroleum products (as of 5 February 2023) to third countries, and the related provision of technical assistance, brokering services or financing or financial assistance. The Council Decision also contained an exemption for these prohibitions should the oil be purchased below a pre-established price cap.
Today's decision sets the level at which the exemption applies and introduces a transition period of 45 days for vessels carrying crude oil originating in Russia, purchased and loaded onto the vessel prior to 5 December 2022 and unloaded at the final port of destination before 19 January 2023. It also sets a transition period of 90 days after every price cap change, to ensure coherent implementation by all operators.
An "emergency clause" is also introduced ( Council Regulation (EU) 2022/2367 amending Regulation (EU) No 833/2014 which allows the transport of oil beyond the price cap or the provision of technical assistance, brokering services or financing or financial assistance related to the transport, when necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted an eighth package of sanctions .
This package:
In relation to transport, Council Regulation (EU) 2022/1904 amends Regulation (EU) No 833/2014 and includes the following measures:
Oil Transport Services
This Regulation introduces the basis to put in place a price cap relating to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries.
It will be prohibited to provide maritime transport and to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil (as of 5 December 2022) or petroleum products (as of 5 February 2023) which originate or are exported from Russia.
The price cap derogation would allow for such transport and services if the oil or petroleum products are purchased at or below a pre-established price cap. This new prohibition will apply as of the date in which the Council will unanimously decide to introduce the price cap.
Maritime
The EU has withdrawn recognition of the Russian Maritime Register of Shipping. Furthermore, the EU port and lock access bans for Russian flagged vessels are now extended to vessels certified by it and it is also subject to the transaction ban.
Listed Persons/Entities
Council Implementing Regulation (EU) 2022/1906 amends Regulation (EU) No 269/2014 adding 30 individuals and 7 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures. The aircraft manufacturer JSC Irkut Corporation is now listed.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a “ maintenance and alignment ” package of sanctions.
This package:
In relation to transport, Council Regulation (EU) 2022/1269 amends Regulation (EU) No 833/2014 extending the port access ban on Russian flagged ships to locks in order to ensure full implementation of the measure and avoid circumvention.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a sixth package of sanctions.
In relation to Russia, this package:
In relation to Belarus, this package expands the list of:
Russia
In relation to transport, Council Regulation (EU) No 2022/879 amends Regulation (EU) No 833/2014 and includes the following measures:
Oil
The Regulation introduces a phased ban on Russian oil imports as well as certain services related to such imports.
For seaborne crude oil, spot market transactions and execution of existing contracts will be permitted for six months, while for petroleum products, these will be permitted for eight months.
Member States who have a particular pipeline dependency on Russia can benefit from a temporary exemption and continue to receive crude oil delivered by pipeline, until the Council decides otherwise. However, Member States benefiting from this exemption will not be able to resell such crude oil and petroleum products to other Member States or third countries.
Due to its specific geographical exposure, a special temporary derogation until the end of 2024 has been agreed for Bulgaria which will be able to continue to import crude oil and petroleum products via maritime transport. In addition, Croatia will be able to authorise until the end of 2023 the import of Russian vacuum gas oil which is needed for the functioning of its refinery.
Oil Transport Services
After a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries.
Listed Persons/Entities
Council Implementing Regulation (EU) 2022/878 amends Regulation (EU) No 269/2014 adding 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures. These include some aircraft and tyre manufacturers and an aircraft repair plant.
Belarus
Council Implementing Regulation (EU) 2022/876 amends Regulation (EC) No 765/2006 adding 12 individuals and 8 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures. This includes one of the largest logistics companies in Belarus and a manufacturer of public transport vehicles.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a fifth package of sanctions. This package has six elements:
(i) Import ban on coal from Russia;
(ii) Financial measures including a full transaction ban and asset freeze on four Russian banks;
(iii) Ban on Russian flagged vessels from accessing EU ports and a ban on Russian and Belarussian Road transport operators working in the EU;
(iv) Further targeted export bans;
(v) Additional import bans;
(vi) Excluding Russia from public contracts and European money; legal clarifications and enforcement.
In relation to transport, Council Regulation (EU) 2022/576 amends Regulation (EU) No 833/2014 and includes the following measures:
The Regulation introduces a prohibition on access to EU ports for Russian registered (“flagged”) vessels after 16 April 2022. A “vessel” is defined as:
(a) a ship falling within the scope of the relevant international conventions;
(b) a yacht, of 15 metres in length or more, which does not carry cargo and carrying no more than 12 passengers; or
(c) recreational craft or personal watercraft as defined in Directive 2013/53/EU of the European Parliament and of the Council
This prohibition does not apply to vessels in need of need of assistance seeking a place of refuge, of an emergency port call for reasons of maritime safety, or for saving life at sea. Furthermore, derogations can be applied for the import/transport into the EU of specified products including natural gas and oil as well as for humanitarian purposes.
The Regulation also introduces a ban on the transport of goods within the EU, including transit, by road transport undertakings established in Russia.
This prohibition does not apply to mail services and goods in transit through the EU between Kaliningrad Oblast and Russia (provided the goods themselves are not banned). Derogations can be applied for the import/transport into the EU of specified products including natural gas and oil as well as for humanitarian purposes.
A prohibition is introduced on the purchase, import, or transfer, directly or indirectly of specified goods including the following transport vehicles:
These measures came into effect on 9 April 2022.
Council Implementing Regulation (EU) 2022/581 amends Regulation (EU) No 269/2014 and now lists specified Russian shipyards and military aviation suppliers.
These measures came into effect on 8 April 2022.
In relation to transport, Council Regulation (EU) 2022/577 amends Regulation (EC) No 765/2006 and includes the following measures:
The Regulation also introduces a ban on the transport of goods within the EU, including transit, by road transport undertakings established in Belarus.
This prohibition does not apply to mail services and goods in transit through the EU in order to return to Belarus. Derogations can be applied for the import/transport into the EU of specified products including natural gas and oil as well as for humanitarian purposes.
These measures came into effect on 9 April 2022.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a a fourth package of sanctions introducing further sanctions for Russia and adding 15 persons and 9 entities to the list of persons, entities and bodies subject to restrictive measures.
In relation to transport, Council Regulation (EU) 2022/428 amends Regulation (EU) No 833/2014 and provides that in relation to a prohibition on supplying, transferring or exporting certain technologies listed in Annex II of Regulation (EU) No 833/2014, or participating in or financing the energy sector in Russia, a derogation is possible where such activity is necessary for ensuring critical energy supply in the EU. Furthermore, a prohibition is introduced on the sale, supply, transfer or export of specified luxury goods, including certain transport vehicles and related goods, to or for use in Russia.
These measures came into effect on 16 March 2022.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted further sanctions, expanding on and clarifying existing sanctions concerning Russia and Belarus. In particular, the new measures impose restrictive measures on 160 individuals and amend existing Regulations to help ensure even more effectively that Russian sanctions cannot be circumvented, including through Belarus.
In relation to transport, Council Regulation (EU) 2022/394 amends Regulation (EU) No 833/2014 to prohibit the supply, transfer or export of certain maritime navigation goods and technology, or related technical or financial assistance, to, or for use in, Russia (or, for goods and technology, the placing on board of Russian-flagged vessels). It also adds the Russian Maritime Register of Shipping to the list of state-owned enterprises subject to financing limitations and introduces a prior information sharing provision for specified authorised exports of, or specified authorised provision of technical or financial assistance for, maritime safety equipment to Russia.
These measures came into effect on 10 March 2022.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted further sanctions following Russia’s invasion of Ukraine. The measures relate to the finance sector (incl. restricting access to SWIFT) and disinformation and also impose sanctions on 22 high ranked members of Belarussian military personnel and limit trade between the EU and Belarus.
In relation to transport, Council Regulation (EU) 2022/355 amends Regulation (EC) No 765/2006 to include a prohibition on the sale, supply, transfer or export of dual-use goods and technology,* or related technical or financial assistance, which might contribute to its military and technological enhancement, to Belarus. Certain derogations are available but if the goods or technology, or related technical or financial assistance, is intended for the aviation industry these do not apply.
*Dual-use goods and technology means the items listed in Annex I to Regulation (EU) 2021/821.
These measures came into effect on 2 March 2022.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a third package of sanctions against Russia following Russia’s invasion of Ukraine. This third package included measures relating to aviation and finance. It also added 6 persons and one entity to the list of persons, entities and bodies subject to restrictive measures including an asset freeze, a prohibition on making funds available to those listed, and a travel ban preventing listed persons from entering or transiting through EU territory. These measures came into effect on 28 February 2022.
In relation to the transport measures, Council Regulation (EU) 2022/334 provides that EU member states will deny permission to land in, take off from, or overfly their territories to any aircraft operated by Russian air carriers, including as a marketing carrier, or to any Russian registered aircraft, or to non-Russian registered aircraft which are owned or chartered, or otherwise controlled by a Russian legal or natural person with certain exceptions and derogations.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
The EU adopted a second package of sanctions against Russia following Russia’s invasion of Ukraine. The measures in this second package cover the financial sector, the energy and transport sectors, dual-use goods, export control and export financing, visa policy, additional sanctions against Russian individuals and new listing criteria. These measures came into effect on 26 February 2022.
In relation to transport, Council Regulation (EU) 2022/328 includes a prohibition on the sale, supply, transfer or export of aircraft, aircraft parts and equipment to Russia, as well as restrictions on aircraft repair and maintenance by EU operators (with some exemptions for safety reasons), and on insurance and reinsurance.
Specifically, the Regulation prohibits:
Some limited exemptions are provided for in the Regulation with regard to the goods listed in Annex XI of the Regulation.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
the EU adopted a package of sanctions to respond to the decision by the Russian Federation to recognise the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities. The sanctions package came fully into effect on Thursday, 24 February.
The sanctions package comprises targeted restrictive measures on a number of individuals and entities, restrictions on economic relations with the non-government controlled areas of the Donetsk and Luhansk oblasts, and financial restrictions against Russia.
Preparations of a second, more extensive EU sanctions package, are underway in response to Russia’s subsequent attack on Ukraine.
Under Council Regulation (EU) 2022/263 the measures include provisions restricting certain trading activities with the non-government controlled Ukrainian territories of Donetsk and Luhansk. These controls include certain goods and technology for use in the transport sector. The full list of items to which the restrictions apply is specified in Annex II to the Regulation.
Specifically, the Regulation provides that:
The Regulation includes provisions for a number of partial and temporary exemptions and for contracts concluded prior to the sanctions coming into effect.
For further information, contact: eucpd@transport.gov.ie
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.