EU sanctions – latest updated FAQs on the carriage of certain Russian cargoes including coal and fertilisers

On 10 August 2022 the European Union (EU) published FAQs which stated that the transport of Russian coal, solid fossil fuels and certain fertilisers (and the provision of insurance for the carriage of these goods) to any destination i.e. whether inside or outside the EU would be in breach of EU sanctions (pursuant to EU Council Regulation (EU) 833/2014) (the EU Regulation). 

On 19 September 2022, the EU amended these FAQs by confirming that the transport of these goods from Russia to non-EU countries is not prohibited. 

On 7 October 2022, these FAQs were amended once again. A copy of them can be found here. The latest FAQs provide that: 

• the transport of wood, charcoal and coal (as listed in Annex XXI and Annex XXII of the EU Regulation) from Russia to a non-EU country and related insurance is only permitted providing it does not involve transit through the territory of the EU. 
• the scope of wood products which are permitted to be transported from Russia to a non-EU country has been narrowed from all products with CN code 44, to only fuel wood with CN code 4401 and charcoal with CN code 4402.
• the transport of fertiliser and animal feed (as listed in Annex XXI of the EU Regulation) from Russia to a non-EU country and related insurance is permitted even when it involves transiting through EU territory. 
• certain hydrocarbons falling under CN codes ex2901 and 2902 and cement products falling under CN codes 2523 and 6810 (as listed in Annex XXI of the EU Regulation) have been removed from the list of permitted products which can be transported from Russia to non-EU countries. 

A copy of the IG Circular dated 1 November 2022 which provides full details of the amendments made to the FAQs since they were issued on 10 August 2022 can be found here. 

If members have any queries regarding the above, please get in touch with your usual club contact. 

Categories: Sanctions, Ukraine / Russia