By Tommaso Fonti, LL.M.Customs and Transport Law Area

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The recent EU restrictive measures related to the trade of goods with Russian, Belarusian and Donbass counterparts concern:

1) a ban on the export of dual-use goods and almost dual-use goods, i.e., goods that can otherwise contribute to Russian military and technological upgrades, including inverters, variable frequency drives, air filtration systems, motors, optical detectors, sensors, and semiconductors;

2) the export of goods and technologies suitable for use in a number of key sectors such as: transport; telecommunications; energy; exploration, prospecting and production of oil, gas and mineral resources; aviation and space industry;

3) the importation into the EU of any goods from the territories of Doneck and Lugansk, which are no longer subject to Ukraine following the Russian occupation.

The rules on restrictive measures provide that the above-mentioned prohibitions do not apply under certain conditions.

The regulations on restrictive measures also provide for specific information and authorization requirements for economic operators, as well as controls by the Customs Authority. To this end, the European Commission has updated the Taric database, integrating the restrictive measures and inserting specific codes with which traders can self-certify, in the customs declaration, any exceptions.

In Italy the Customs and Monopolies Agency, with Memorandum no. 99410/2022, issued the new regulations for trade with Russia and Ukraine, highlighting the prohibitions, restrictions and obligations for economic operators.

In case of violation of the prohibitions and restrictive measures imposed by the EU Regulations towards the territories subject to trade embargo, penal sanctions are applied, as well as the confiscation of the goods or the confiscation for equivalent.

Bacciardi Partners is available to assist companies in carrying out objective checks on goods and services subject to the above prohibitions and restrictions.