Foreign trade: New EU regulations in connection with export controls

  • 12/27/2023
  • Reading time 2 Minutes

In addition to the 12th sanctions package against Russia, the EU has also adopted Delegated Regulation (EU) 2023/2616 amending Annex I of the EU Dual-Use Regulation.

12th sanctions package: overview of trade measures

The 12th sanctions package tightens or introduces various (new) trade measures:

  • Import bans on Russian diamonds.
  • Import bans on certain metal goods from Russia, in particular raw materials for steel production, processed aluminum products and other metal goods.
  • New import ban on liquefied petroleum gas (LPG).
  • Export bans on other dual-use goods and advanced technology and industrial goods, including chemicals, thermostats, DC motors and servomotors for unmanned aerial vehicles, machine tools and machine parts, batteries and industrial goods from the construction sector.
  • Prohibition on the provision of business and design software.
  • In the energy sector, the monitoring and enforcement of the oil price cap is to be improved through further measures such as monitoring the sale of tankers to third countries.

In addition, the 12th sanctions package includes an expansion of the personal sanctions list by over 140 individuals as well as further tightening of obligations in connection with the freezing of assets. The 12th sanctions package is completed by new and stricter measures to combat circumvention practices.

EU Dual-Use Regulation

Delegated Regulation (EU) 2023/2616 amended Annex I to the EU Dual-Use Regulation (Regulation (EU) No. 2021/821). Annex I is a list of goods that are subject to an export license requirement under EU law. For the major part, this only concerns editorial adjustments, but individual updates also affect the material conditions of the classification of goods. The Delegated Regulation is available here.

The amendment to Annex I of the EU Dual-Use Regulation came into force on December 16, 2023. Companies should review the existing classification of goods in the company based on the amended lists of goods and adjust them if necessary.

Further information on the 12th sanctions package and the amendments to Annex I to the EU Dual-Use Regulation in the online seminar:

Customs and foreign trade law update
Case law, current developments and supply chain obligations
Wednesday, January 24, 2024, 10:00 a.m. until ca. 11:30 a.m.

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Authors of this article

Sebastian Billig


Attorney-at-Law (Rechtsanwalt)

Sven Pohl


Attorney-at-Law (Rechtsanwalt)

Mareike Höcker


Attorney-at-Law (Rechtsanwältin)

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