In their latest FAQs, the EU clarifies that the ban placed on coal products exported from Russia includes a prohibition on products destined for non-EU members. Until this point, it was widely interpreted that the purchase, import, or transfer of Russian-origin coal was restricted only for purchases destined for EU member states.
Taking into account these latest FAQs, EU persons are now prohibited from:
- Purchasing Annex XXII coal products of Russian origin or those which are exported from Russia
- Transporting such goods irrespective of their destination
- Importing them into the EU
As our global trade team discusses in their latest alert, these FAQs not only hinder the movement of Russian-coal to EU states and third countries, but also that of certain fertilizer products. Given this goes against the EU’s previous statements about not restricting agricultural and food products between non-EU countries and Russia, it is likely more revisions will be made to this legislation.