Which products are covered by the sanctions against Russia?

The impact of sanctions on Russian imports and exports

Always check if your products fall under the sanctions before you export products or services to Russia, or if you import products from Russia. To find out if you can import or export a certain product from or to Russia, consult the EU article on the sanctions. This provides a summary of all sanctions packages plus links to the relevant regulations. The lists of products that you cannot export to or import from Russia are published in the annexes to the EU regulations.

The EU has also imposed sanctions on Belarus in response to the country’s involvement in Russia’s aggression against Ukraine. This sanctions regime consists of a range of financial, economic, and trade measures.

Information provided by the Netherlands Enterprise Agency

The Netherlands Enterprise Agency (RVO) maintains a database of products on the sanction lists, as well as sector-specific information. This information is available only in Dutch. However, links to the EU regulations in English are often available. You can also search in the annexes for specific commodity codes (HS codes).

Exemptions to the ban

Exemptions to the export and import ban can only be provided under certain circumstances. If your product appears on any of the sanction lists, but you think it meets the criteria for an exception, you must apply for an exemption permit.

Possible exemptions include products with one of these purposes:

• Humanitarian purposes and emergencies
• Medical and pharmaceutical purposes
• Temporary export for use by news media
• Software updates
• Consumer communications devices
• Personal goods used by natural persons travelling to Russia, not intended for sale
• Cooperation between the EU, the Member States, and Russia towards purely civilian matters
• International cooperation for space programmes
• Matters of nuclear and maritime safety
• Civilian telecommunications
• Use by subsidiaries and branches of EU and partner country entities
• Diplomatic missions of the EU, the Member States, or a partner country
• Services to guarantee cybersecurity and information safety for natural persons, legal persons, and organisations. The Russian government and businesses directly or indirectly controlled by it are excluded

If your product qualifies, apply for an exemption permit from the Central Import and Export Office (CDIU). Download the application form (in Dutch).

You can also contact RVO by email or telephone for advice about sanctions and exemptions. This page is in Dutch but you can ask your question in English.

Military end-users and dual-use goods

You cannot apply for an exemption permit if your product will be exported to a military end-user in Russia. Check the full list of entities that automatically count as military end-users.

If you intend to export dual-use goods that may qualify for an exemption permit, a valid export licence is needed.