Stricter Dual-Use Regulation for export goods to Russia
Since 26 February 2022, European exporters are prohibited from shipping various dual-use goods and goods related to dual-use to Russia. Some points of attention.
A complete ban has been in force since the day of publication:
Sale, supply, transfer or export of all dual-use goods listed in Annex I of Regulation (EU) 821/2021, as amended, to Russia or for use in Russia (Article 2(1)).
Sale, supply, transfer or export of all dual-use items listed in Annex VII of Regulation (EU) 833/2014 as amended by this Regulation (EU) 2022/328 (Article 2a(1)).
Also the provision of technical assistance or brokering of these items for use in Russia or by persons in Russia is prohibited (Article 2(2) and 2a(2)).
There are several exceptions, which are subject to a strict prior authorization policy.
Every economic operator is obliged to verify himself whether the goods he sells/delivers/transfers or exports are covered by the dual-use regulation according to the technical description in Annex I of Regulation 821/2021 and Annex VII of Regulation 833/2014.
Similar rules apply to sales, supplies, transfers or exports to Belarus, contained in Regulation (EU) 2022/355.
We advise clients to always consult the official sources of law before delaying an export declaration and not to rely on the Belgian “Tarbel” website, which unfortunately is not always up to date.
Regulation (EU) 2022/328 (Russia)
Regulation (EU) 2022/355 (Belarus)
