On 26 July 2022, the European Commission updated its Frequently Asked Questions (FAQs) on Article 3m(3) a&b and 3m(10) of Council Regulations 833/2014 in regards to the reporting obligations under the oil import restrictions that were included to the EU’s sixth package of sanctions against Russia.

As a reminder, the sixth sanctions package contains a complete import ban on all Russian seaborne crude oil and petroleum products. This covers 90% of EU’s current oil imports from Russia. The ban is subject to certain transitional periods to allow the sector and global markets to adapt along with certain reporting requirements. A temporary exception has been included for imports of crude oil by pipeline into those EU member states that, due to their geographic situation, are especially dependent on Russian supplies and have no viable alternatives.

Among other things, the FAQs importantly clarify that imports should only be reported by the Member State in which the goods first enter the EU's customs territory, even if the goods are for further delivery in another Member State.

The EU’s updated FAQs can be found here.

Our recent blog post on the sixth EU package of sanctions can be found here.

Our updated table of EU sanctions can be found here.