EU introduces 16th package of sanctions against Russia

EU introduces 16th package of sanctions against Russia; and UK announces 'largest sanctions package against Russia since 2022'

On 24th February 2025 (the third anniversary of Russia’s invasion of Ukraine), the European Union (EU) issued its 16th package of sanctions against Russia. These include measures targeting Russia’s energy, trade, infrastructure, and transport sectors (among others) found in Council Regulation (EU) 2025/395, which further amends Council Regulation (EU) 833/2014 (the “Regulation”). Key highlights relating to shipping include:

Commodities

Aluminium - A direct import ban into the EU from Russia of primary aluminium (previous measures included a prohibition on importing processed aluminium goods from Russia). During an initial 12-month transitional period, a quota mechanism has been introduced, allowing for 275,000 tonnes of aluminium (i.e. 80% of EU imports in 2024). By the end of 2026, no Russian aluminium can be imported into the EU.

Additional export bans have been placed on chemicals, chrome, and other products essential for precision machine tools, crucial for Russia's industrial and military capabilities.

The existing prohibition on providing goods, technology, and services for the completion of Russian LNG projects has been extended to apply to crude oil projects in Russia, such as the Vostok oil project. Members are reminded that contracts for the transhipment of Russian LNG within the EU (for the avoidance of doubt, transhipment in this context would include STS transhipment and where cargo is discharged ashore temporarily and then reloaded onto a ship) that were signed before June 2024 are subject to a wind-down period, up until 26th March 2025.

Export restrictions have been introduced on dual-purpose items such as video-game controllers and flight simulators where they can potentially be used for military/combat operations.

Full 'transaction' ban on Russian ports

A full ‘transaction’ ban on Russian ports (and airports), with immediate effect, which are believed to have been used to transport combat-related goods and technology, or to circumvent the oil price cap by transporting Russian crude oil via ships in the shadow fleet. The restrictions are broadly drafted and will apply to any relevant port call even if there is no direct transaction with the port authorities themselves.

The banned ports are the Volga port, Astrakhan, and Makhachkala port on the Caspian Sea, and sea ports Ust-Luga and Primorsk on the Baltic Sea, and Novorossiysk on the Black Sea.

Exceptions to the port ban

There are some exemptions to the port ban for the carriage of certain foodstuffs and fertilisers, earth metals such as titanium, aluminium, copper, nickel, palladium, and iron ore, medicine, and pharmaceuticals depending on their destination. Notably, coal does not form part of the exceptions, which is regularly loaded from these ports.

In respect of the Russian price cap, compliant Russian oil and refined petroleum products and oil from third-party countries, such as Kazakh oil, will be allowed. However, the EU now completely prohibits temporary storage or the placement under free zone procedures of Russian crude oil or petroleum products within the EU. This was previously allowed if the oil complied with the price cap and ultimately went to a third-party country.

Caution and specific advice for all these trades is always recommended.

Additionally, a vessel in need of assistance seeking a place of refuge, an emergency port call for reasons of maritime safety, saving life at sea, or for the urgent prevention of damage to the environment, port calls will be permitted.

Ships targeted

The EU has listed an additional 74 ships that form part of the shadow fleet or contribute to Russia’s energy revenues, bringing the total number of listed ships to 153. These ships are subject to a port access ban, and it is prohibited to provide a range of maritime services to them.

There is also a new listing criterion, targeting those who ‘support’ the operations of unsafe oil tankers. Further information can be found by following this link: European Commission Press Corner.

UK sanctions

The UK has also updated its list of sanctioned entities and individuals, including non-Russian nationals. 107 additional entities, individuals, and ships have been listed under the UK Russia (Sanctions) (EU Exit) Regulations 2019, bringing the total listed ‘shadow vessels’ to over 130. The new listings include:

• Certain Russian state-owned entities and importers of dual-use goods, involved in the Russian defence sector;
• Certain third-country producers and suppliers of machine tools, electronics, and dual-use goods supporting or enabling Russia’s defence industry. Further information can be found by following this link: UK Government News.

In summary

EU foreign affairs and security chief Kaja Kallas stated: “This new round of sanctions not only targets the Russian shadow fleet but those who support the operation of unsafe oil tankers, video game controllers used to pilot drones, banks used to circumvent our sanctions, and propaganda outlets used to spout lies.”

A link to the European Commission Q&A relating to this latest round of measures can be found here: FAQs.