Dear clients,

In connection with the legal update from April 8, 2022, which contained a preliminary list of the contents of the fifth package of anti-Russian sanctions, we would like to inform you that the EU Regulation containing the fifth package of anti-Russian sanctions in connection with the ongoing crisis in Ukraine, is already available in the Journal of the European Union, namely Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014, concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine („Regulation 2022/576“), available here.

Regulation 2022/576 extends the anti-Russian sanctions already in force and also imposes new sanctions. In particular, the list of goods and technologies prohibited from being imported or exported from Russia has been significantly expanded, in particular:

• A prohibition to purchase, import or transfer of goods listed in Annex XXI of Regulation 2022/576, such as:

 Wood and wood products;

 Furniture;

 Certain chemical compounds used in the manufacture of plastics

 Fertilisers;

 Cement;

 Jet engines;

 Boats;

 Seafood etc.

However, the prohibition do not yet apply to imports of titanium, aluminium, copper, nickel, palladium, iron ore, oil and natural gas.

• Prohibition of sale, supply, export of goods listed in Annex XXIII of Regulation 2022/576, such as:

 Chemical compounds/products, rare metals, minerals and petroleum derivatives, etc.;

 Polymers and similar substances;

 Dyes, varnishes, coatings, surface treatment products, solvents, thinners;

 Lubricants;

 Wood, wood products, plastics, paper, metal products, rubber and rubber products, ceramic and stone products;

 Fabrics, yarns, natural and synthetic fibres, textiles;

 Glass and glass products;

 Iron products (sheets, tubes, profiles, bars, wires, semi-finished products, steel and steel products;

 Products from aluminium and other metals;

 Boilers, furnaces, engines, turbines;

 Various types of machines, tools, vehicles and their components.

However, the above prohibitions shall not apply until 10 July 2022 to the performance of contracts concluded before 9 April 2022 or to supplementary contracts necessary for the performance of such contracts. As far as framework contracts are concerned, in order for a framework contract to be considered a contract within the meaning of the relevant Regulation for the purposes of the exemptions provided for the performance of contracts concluded before 9 April 2022, it must be sufficiently specific, inter alia, as regards the quantity and price of the goods to be supplied.

Please note that the above export/import prohibitions are also accompanied by a prohibition on the provision of any technical assistance or other services related to the manufacture, maintenance of the above goods or technology.

The above lists are generalized and do not reflect all goods subject to anti-Russian sanctions. If you believe that you or your company are affected by anti-Russian sanctions, please do not hesitate to contact us for an analysis of the impact of sanctions on specific goods or technologies. Please also note the import/export restrictions resulting from previous regulations, which we have addressed in previous legal updates.

In case of any questions about the above, we of course remain available to you.