Consolidated version on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 [Version of 12 September 2023]

The EC has published an updated consolidated version of its FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 in light of the ongoing conflict in Ukraine. The consolidated version includes FAQs concerning EU sanctions adopted following Russia’s military aggression against Ukraine.
Below we would like to present the new questions in full, together with a brief summary of the corresponding answers:
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Section D „TRADE AND CUSTOMS.“, topic 5 „IMPORT, PURCHASE AND TRANSFER OF LISTED GOODS“
New Question 13 (p. 169) Can Russian nationals temporarily bring personal goods and vehicles listed in Annex XXI and subject to the prohibition in Art. 3i of Council Regulation 833/2014 into the Union, e.g. for touristic travels?
Answer: According to the European Court of Justice, sanctions should be interpreted broadly in order to ensure their effectiveness and prevent circumvention. National authorities are responsible for assessing each situation and implementing the sanctions accordingly. Article 3i of Council Regulation 833/2014 prohibits the purchase, import, or transfer of goods listed in Annex XXI if they originate in or are exported from Russia. This includes motor vehicles falling under CN code 8703. Motor vehicles are particularly prone to circumvention, so authorities need to pay attention to them. The use of the vehicles, whether private or commercial, is not relevant as long as they fall under the listed CN code and are from Russia. This is typically the case for vehicles with a Russian license plate and registration. The duration of their stay in the Union and the customs procedures they undergo are also not relevant. For goods with minimal circumvention concerns, such as personal hygiene items or clothing for travelers, authorities should apply the prohibition in a proportional and reasonable manner.