Which products are covered by the sanctions against Russia?

Published by:
Netherlands Enterprise Agency RVO
Netherlands Enterprise Agency RVO
Netherlands Chamber of Commerce, KVK
Netherlands Chamber of Commerce, KVK
2 min read

There are currently extensive European sanctions in place against Russia. This can affect your business if you export products to, or import products from Russia or Ukraine. Do you need to supply products or services to Russia? Learn more about what is allowed and what you must do.

The impact of sanctions on Russian imports and exports

Always check if your products fall under the current 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 article 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 sanctions against Russia are also explained in this article. It summarises, for example, the sanctions relevant to specific sectors or products.

Information provided by the Netherlands Enterprise Agency

The Netherlands Enterprise Agency maintains a database of products on the sanction lists, as well as sector-specific information. This information is available only in Dutch, but links to the EU regulations in English are often available.

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.

There are 3 categories for possible exemptions.

Category 1

Products with one of the following 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.

Category 2

Products with one of the following purposes:

  • 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.

Category 3

If your product is listed in Annex I of Regulation 2021/821 or Annex VII of Regulation 833/2014, but does not meet the exemption requirements of categories 1 and 2, you may still be able to obtain a permit, if:

  • these products are needed for the fulfilment of contracts concluded before 26 February 2022.
  • the permit was requested before 1 May 2022.

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

Please note: If you are granted an exemption permit, you must still follow all standard export procedures that apply to your product.

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.

Questions relating to this article?

Please contact the Netherlands Enterprise Agency, RVO