October 4, 2023

EU updates FAQs to provide guidance on new export restrictions on dual-use goods

On October 2, 2023, the Council of the EU issued new frequently asked questions (“FAQs”) on export-related restrictions upon dual-use goods imposed pursuant to sanctions concerning Russia’s actions that destabilize the situation in Ukraine and, in particular, the restrictions introduced in Articles 2, 2a and 2b of Council Regulation 833/2014 (“the Sanctions Regulation”).  The FAQs provide guidance on situations that are covered by the exemptions under the Sanctions Regulation and derogations where authorization must be requested from the competent authority.  The Council also confirms, in the FAQs, that the Sanctions Regulations cover the export of controlled goods shipped in transit through Russia by land to third countries.  There is also a new discussion on how the EU verifies that covered items exported to third countries are not re-exported to Russia as well as an amended list of common high priority items in Annex II.

FAQs – Export-related Restrictions for Dual-Use Goods and Advanced Technologies