This article examines the EU’s new regulatory measures, their implications, compliance challenges, and shortcomings, alongside an overview of parallel steps taken by the UK government.
In brief
- The EU now prohibits the purchase, import, or transfer—directly or indirectly—of petroleum products under CN 2710 where those products were refined in a third country from Russian‑origin crude oil (CN 2709 00).
- Certificates of origin are required where importers cannot rely on a presumption of non‑Russian origin or a partner‑country exemption.
- Technical assistance, brokering services, financing, insurance, and re‑insurance connected with such products are also prohibited.
- The United Kingdom maintains a parallel sanctions regime targeting Russian crude and petroleum products but has not yet introduced an equivalent measure covering CN 2710 products refined in third countries from Russian crude. Further measures are anticipated.
The Regulation in question
- Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (as amended)
- FAQs on sanctions against Russia and Belarus, with focus on the following provisions: Article 3ma of Council Regulation (EU) No 833/2014.
EU Regulatory framework
Regulation (EU) No 833/2014 forms the foundation of the EU’s sanctions regime against Russia. Although repeatedly amended over the past decade, its overall structure has remained consistent while the list of prohibitions has expanded and become increasingly complex.
The EU has progressively tightened restrictions on Russia’s oil sector, prohibiting the purchase, import, or transfer of crude oil and petroleum products originating in or exported from Russia. These measures have also extended to service providers—brokers, insurers, financial advisers, and others—who risk breaching sanctions when participating in transactions involving such products.
The latest amendments seek to address a key design flaw: the continued entry of refined products made from Russian crude but processed in third countries.
Council Regulation (EU) 2025/1494
Since 21 January 2026, the EU bans the purchase, import, or transfer – directly or indirectly into the EU – of petroleum products under CN 2710 when they have been refined in any third country (sanctioned or unsanctioned) from
Russian‑origin crude oil classified under CN 2709 00.
This prohibition is limited to CN 2710 products. Other goods refined from Russian crude oil fall outside its scope.
This raises several practical questions: How should importers evidence compliance? What is required when petroleum is sourced from a country with both domestic and imported crude supplies?
4.1. Complicated compliance
4.1.1. Determining origin
Importers must be able to demonstrate the origin of the crude oil used to refine CN 2710 products in a third country. Products imported from “partner countries” (Canada, Norway, the United Kingdom, the United States, and Switzerland) benefit from a presumption of non‑Russian origin unless rebutted.
Additionally, products imported from third countries that were net exporters of crude oil in the previous calendar year are presumed to derive from domestic (i.e., non‑Russian) crude unless a competent authority has reasonable grounds to conclude otherwise.
Whether certificates of origin will meaningfully prevent Russian‑derived molecules from entering the EU market remains uncertain.
4.1.2. It’s about how you carry, not what you carry
The European Commission has clarified that de minimis residues of Russian oil in containers or tanks do not render a cargo Russian‑origin. More controversially, it has suggested that vessels may use bunker fuel that contains Russian‑origin molecules.
The Commission further states that EU‑flagged vessels are not required to verify the origin of crude used to produce their bunker fuel, provided the bunkers are necessary for the voyage. Operators should be cautious: this narrow clarification does not mitigate exposure where they are otherwise involved with Russian‑origin petroleum.
4.1.3. Emergency
EU ports may still serve as places of refuge for safety‑of‑life or emergency reasons, provided no commercial services are supplied. However, the extent of permissible assistance remains unclear, leaving operators exposed to interpretive risk.
4.2. Service providers
The expansion of the prohibition now captures services related to CN 2710 products refined in third countries from Russian crude. This creates significant challenges for service providers—insurers, brokers, financiers, surveyors—who must ensure compliance despite the scientific impossibility of chemically proving origin.
Experts already commented that it is virtually impossible to fully dissect a product to a molecular level and demonstrate the precise origin of the constituting elements. The EU expects operators to rely on risk‑based attestation and due diligence.
To support compliance, operators should:
- Ensure full documentary traceability across the production and supply chain;
- Apply enhanced due diligence for products shipped from or through high‑risk jurisdictions such as Turkey, India, or China;
- Insert robust contractual protections, including warranties of non‑Russian origin, indemnities, audit rights, documentation obligations, and termination clauses.
- Refusal by a counterparty to agree to such terms may itself be a red flag.
Blacklisted vessels
In addition to the further restrictive measures on Russian oil products, the EU has increased the number of blacklisted vessels, which should be consulted regularly (see links at the top).
Furthermore, the EU has amended the list of prohibitions in relation thereto, which now also include reinsurance. As a reminder, it is prohibited to directly or indirectly:
- provide access to ports, anchorage zones and locks in the territory of the Union, and for such a vessel to access them;
- import into the Union, purchase or transfer such a vessel;
- sell, supply, including charter, or export such a vessel;
- operate or crew such a vessel;
- provide flag registration for the benefit of such a vessel;
- provide financing and financial assistance, including insurance and reinsurance, as well as brokering services, including ship brokering;
- provide technical assistance and other services including bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services to the benefit of such a vessel; and
- engage in ship-to-ship transfers or any other transfer of cargo with, or procure any services from, such a vessel.
United Kingdom
The approach adopted by the UK has largely been similar as the one adopted by the EU. The UK has, however, stopped short of banning refined products on the basis of CN Code 2709 00 or 2710. It is expected that the UK will take similar sanctions, as announced in October of last year.
Some UK officials have indicated that existing statutory powers could, in theory, support cooperation with international enforcement actions against shadow‑fleet vessels. The extent to which the UK would participate in interdiction operations remains unclear.
At this stage, it appears that the majority of stakeholders are more concerned with potential accidents involving the uninsured fleet of tankers. Perhaps one can help prevent the other. It is not known if and to what extent the UK may initiate or assist with the seizing of tankers.
For now it should be noted that the UK has adopted a similar approach as the EU, and:
- Also has a blacklist of the vessels, which can be found here, together with other sanction lists;
- Introduced a wind-down of transactions in relation to Russian oil following the joint sanctions by the UK, EU and USA on two major Russian oil companies (ie Rosneft and Lukoil), ensuring that companies currently involved with one of the above can timely terminate their dealings and prevent being in breach of sanctions. This wind-down license terminated in November 2025. Previously, the UK had already sanctioned Gazprom Neft and Surgutneftegas in a similar way.
