22.09.2025
News from export control: Russia/Belarus embargo – 18th EU sanctions package of July 18, 2025
![[Translate to English:] Neues aus der Exportkontrolle: Russland-/Belarus-Embargo – 18. Sanktionspaket der EU vom 18.07.2025](/fileadmin/user_upload/Bild_Blog_Neues_aus_der_Exportkontrolle_1.jpg)
For a good year, things appeared relatively calm for importing and exporting companies: While the 14th package of sanctions tightening the embargo on Russia and Belarus on June 24 and 29, 2024, still included such "exotic" and far-reaching innovations as a "best efforts obligation" and a "due diligence obligation" or provided for extensions to the "no-Russia clause" and introduced a "no-Belarus clause" for the first time, the following sanctions packages Nos. 15, 16, and 17 contained no major surprises or significant innovations, at least for trade: As expected, the lists of names and goods were expanded, the best efforts and due diligence obligations and the already familiar service and software bans were extended once again, and the Belarus embargo was brought even more into line with the Russia embargo. However, the focus of the embargo tightening was more on the "shadow fleet," further restrictions on access to airports, ports, and locks, and measures against Russian oil and gas exploration and production. What changes does the 18th package of sanctions of July 18, 2025, bring for importing and exporting companies?
The 18th package of sanctions announced by the EU at the beginning of June 2025 was described in the relevant media as a particularly drastic and harsh measure, if not the harshest since February 2022. Essentially, the aim will be to target two areas in particular: the Russian energy sector and the banking sector. The new EU sanctions package will provide for measures to prevent the recommissioning of Nord Stream 1 and 2, as well as an import ban on Russian gas; the oil price cap will be lowered; additional ships in the shadow fleet will be listed; and an import ban on products refined from Russian crude oil will be imposed. Furthermore, banks involved in circumventing existing sanctions will be sanctioned; the ban on the use of the SWIFT system will be extended to include additional Russian banks; and sanctions will be imposed on the Russian Direct Investment Fund. Fearing a complete halt to supplies of gas, oil, and nuclear fuel from Russia, Slovakia then threatened to veto the prepared sanctions package, and Malta, Greece, and Cyprus also raised concerns, as they feared disadvantages for domestic shipping companies if the oil price cap were lowered too much.
In light of these announcements, trading and distribution companies may have felt that they will not be significantly affected by the 18th package of sanctions. However, the discussion surrounding the energy sector has overshadowed the fact that the EU had also announced further export bans on dual-use goods, critical technologies, and industrial goods, with a focus on machinery, metals, plastics, and chemicals worth more than €2.5 billion, as well as supplementary measures to prevent the circumvention of sanctions, which were then actually implemented with the 18th sanctions package of July 18, 2025 (which came into force on July 20, 2025).