What is the difference between EU export and import sanctions?

Export sanctions restrict selling, supplying or exporting listed goods to a sanctioned country or for use in it, and turn on the destination, end user and end use. Import sanctions restrict purchasing or importing listed goods that originate in or are exported from a sanctioned country, and turn on origin and route. The same CN code can be restricted in one direction and not the other.

Do EU import bans apply to goods shipped through a third country?

Generally, yes. Import measures usually cover goods that originate in the sanctioned country as well as goods exported from it, so routing goods of sanctioned origin through a third country does not take them outside the measure. Whether genuinely processed goods keep their original origin depends on the customs origin rules and, for some measures, on specific provisions about inputs.

Does the EU dual-use regulation restrict imports?

No. The dual-use framework controls exports from the EU, together with brokering, technical assistance and transit. Imports of dual-use items into the EU may still be caught by a country sanctions regime or by other EU or national rules, so they need to be screened separately.

What information do I need to screen a shipment for EU sanctions?

The eight-digit CN code, a precise description and where relevant the technical specification, the direction of movement, the destination, end user and end use for exports, the origin and route for imports, the relevant dates including the contract date, and the value where a measure has a threshold. Counterparties are screened separately against the designation lists.

Guide

EU export and import sanctions on goods

EU trade sanctions restrict goods in both directions, and the two run on different facts. Export restrictions turn on where the goods are going and who will use them. Import restrictions turn mainly on where the goods come from.

Two directions, different trigger facts

Most EU sanctions regulations with trade measures contain two kinds of goods restriction, usually in separate provisions with separate annexes.

Export restrictions typically prohibit selling, supplying, transferring or exporting listed goods, directly or indirectly, to a sanctioned country or for use in it. The deciding facts are the destination, the end user and the end use. Where the goods were made is usually irrelevant: an item manufactured in Asia and sold from an EU warehouse is caught in the same way as one made in the EU.
Import restrictions typically prohibit purchasing, importing or transferring listed goods into the EU where they originate in, or are exported from, the sanctioned country. The deciding facts are the origin of the goods and the route they took. The identity of the EU buyer does not take you outside the measure.

The same eight-digit CN code can therefore be restricted on export to a country but not on import from it, or the reverse. A screen that does not record the direction of movement cannot give a reliable answer.

How the main EU regimes use each direction

The balance between export and import measures differs from regime to regime. In broad terms:

Russia and Belarus. Both regimes contain extensive measures in both directions. On the export side they cover, among others, dual-use goods, advanced technology, industrial goods and luxury goods. On the import side they cover, among others, iron and steel products and a range of other commodities and manufactured goods. See the Russia and Belarus scope pages.
Crimea and Sevastopol, and the non-government-controlled areas of Ukraine. These territorial regimes centre on a prohibition on importing goods originating in the territories, combined with export restrictions on goods and technology for specified sectors. See the Crimea and non-government-controlled areas scope pages.
Anti-torture goods. Regulation (EU) 2019/125 controls both the export and the import of goods that could be used for capital punishment or torture, ranging from outright prohibitions to authorisation requirements.
Dual-use items. The dual-use framework controls exports, together with brokering, technical assistance and transit. It does not restrict imports into the EU. See EU dual-use export controls.

These summaries describe the shape of each regime, not its current contents. Annexes are amended package by package, so always check the consolidated text on EUR-Lex for the date of your transaction. The regulation index lists every EU instrument with trade measures that we track.

Origin is not the same as where the goods were shipped from

Import measures usually reach goods that originate in the sanctioned country or are exported from it. Origin here means non-preferential origin under the customs rules, which for processed goods generally turns on where the last substantial transformation took place. Two consequences follow:

Goods of sanctioned origin remain caught when they are routed through a third country. Re-routing changes the shipping documents, not the origin.
Goods that were genuinely transformed in a third country may acquire that country's origin. A few import measures, notably on certain Russian iron and steel products, go further and also reach goods processed in a third country that incorporate inputs from the sanctioned country.

Origin determinations for processed goods are technical and fact-specific. Where the answer turns on them, take advice rather than relying on a supplier's declaration alone.

Transit, re-export and diversion

The direction of movement is not always a simple export or import. Some measures also restrict transit through the sanctioned country of goods exported from the EU, and for certain categories of goods EU exporters are required to include contractual undertakings that the goods will not be re-exported to the sanctioned country. Exports to third countries that are not themselves sanctioned can still breach EU law if the goods are destined for a sanctioned country, which is why diversion risk is assessed on the end destination rather than the first buyer.

What you need to know about a shipment before you screen it

The eight-digit CN code, because annexes are drawn at that level. See CN codes versus HS codes.
A precise description and, for technical goods, the specification, to test against "ex" entries and technical parameters.
The direction of movement: export, import, transit or re-export.
For exports: the destination, the end user and the end use.
For imports: the origin of the goods and the route they took.
The relevant dates, including when the contract was concluded, because wind-down and contract-execution derogations are time-limited.
The value, where a measure applies only above a threshold.

Then screen the counterparties separately against the designation lists. The sanctions screening overview sets out the full sequence, and the HS code guide covers the classification traps.

When to take specialist advice

Screening narrows the question. It does not answer every case. Take advice from your National Competent Authority or qualified counsel where the outcome depends on an origin determination for processed goods, on ownership or control of a counterparty, on whether a derogation or authorisation is available, or on how two regimes interact. ET CÆTERA also offers consulting and training on these questions.

Screening both directions at scale

TRADESANCTIONS.EU checks HS and CN codes against the export, import and transit restrictions of the EU trade regimes in one pass, maps each hit to the annex and article, and shows the exemptions, derogations and wind-down clauses attached to it, with the Official Journal text in any of the 24 official EU languages.

Frequently asked questions

What is the difference between EU export and import sanctions?: Export sanctions restrict selling, supplying or exporting listed goods to a sanctioned country or for use in it, and turn on the destination, end user and end use. Import sanctions restrict purchasing or importing listed goods that originate in or are exported from a sanctioned country, and turn on origin and route. The same CN code can be restricted in one direction and not the other.
Do EU import bans apply to goods shipped through a third country?: Generally, yes. Import measures usually cover goods that originate in the sanctioned country as well as goods exported from it, so routing goods of sanctioned origin through a third country does not take them outside the measure. Whether genuinely processed goods keep their original origin depends on the customs origin rules and, for some measures, on specific provisions about inputs.
Does the EU dual-use regulation restrict imports?: No. The dual-use framework controls exports from the EU, together with brokering, technical assistance and transit. Imports of dual-use items into the EU may still be caught by a country sanctions regime or by other EU or national rules, so they need to be screened separately.
What information do I need to screen a shipment for EU sanctions?: The eight-digit CN code, a precise description and where relevant the technical specification, the direction of movement, the destination, end user and end use for exports, the origin and route for imports, the relevant dates including the contract date, and the value where a measure has a threshold. Counterparties are screened separately against the designation lists.

Need the answer for a specific HS/CN code: which annex and article apply, and whether an exemption or wind-down is available, in any of the 24 EU languages? Run it through the TRADESANCTIONS.EU checker.