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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 .
8 April: 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.
Full details of sanctions measures in respect of the situation in Ukraine can be found on the Department of Foreign Affair’s website.
15 March: 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.
Full details of sanctions measures in respect of the situation in Ukraine can be found on the Department of Foreign Affair’s website .
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
9 March: 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.
Full details of sanctions measures in respect of the situation in Ukraine can be found on the Department of Foreign Affairs' website.
Please note that this is a summary overview only. The full legal acts should be consulted in all cases.
1-2 March: 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.
28 February: 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.
Full details of sanctions measures in respect of the situation in Ukraine can be found on the Department of Foreign Affair’s website.
25 February: 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.
23 February: 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.
Full details of the sanctions measures can be found on the Department of Foreign Affairs website.
For further information, contact: eucpd@transport.gov.ie
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