the comprehensive sanctions currently in place regarding trade with Russia and Belarus, which may impact certain export contracts. The latest updates, effective as of October 21, are as follows:
- Russia: Exporters must contractually prohibit re-exports to Russia and use in Russia in some instances. More information can be found in Regulation (EU) 2024/1745.
- Belarus: A similar obligation applies to re-exports to Belarus and use in Belarus, as described in Regulation (EU) 2024/1865.
What does this mean for you?
In the context of the sanctions against Russia and Belarus, the Directorate General of the EU Commission (TAXUD) published new codes to declare that a re-export to Russia and Belarus and a re-export for use in Russia and Belarus has been contractually prohibited in accordance with Article 12g of Regulation (EU) No. 833/2014 or Article 8g of Regulation (EC) No. 765/2006 or that these requirements do not apply. The following codes are now available:
Following codes can be used:
- Y227: “Re-export to Russia and re-export for use in Russia have been contractually prohibited in accordance with Article 12g Paragraph 1 of Regulation (EU) No. 833/2014”
- Y228: “Exception from the obligation pursuant to Article 12g Paragraph 1 to contractually prohibit re-export to Russia and re-export for use in Russia pursuant to Article 12g Paragraph 2 Letter b of Regulation (EU) No. 833/2014”
- Y229: Exception from the obligation pursuant to Article 12g Paragraph 1 to contractually prohibit re-export to Russia and re-export for use in Russia pursuant to Article 12g Paragraph 2a of Regulation (EU) No. 833/2014”
- Y230: “Re-export to Belarus and re-export for use in Belarus were contractually prohibited pursuant to Article 8g Paragraph 1 of Regulation (EC) No. 765/2006”
- Y231: “Exception pursuant to Article 8g Paragraph 2 of Regulation (EC) No. 765/2006 from the obligation pursuant to Article 8g Paragraph 1 to contractually prohibit re-export to Belarus and re-export for use in Belarus”
- Y232: “Exception pursuant to Article 8g Paragraph 2 of Regulation (EC) No. 765/2006 from the obligation pursuant to Article 8g Paragraph 1 to contractually prohibit re-export to Belarus and re-export for use in Belarus”
You may receive a demand from the customs authorities to present a copy of the contract.
Do you have questions about these changes, or would you like more information? Please feel free to reach out to us.
