EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – LUXURY GOODS (Post 5)

Following is part 5 of our series on current European Union sanctions against the Russian Federation. Before continuing, be sure to catch up on our previous posts regarding sanctions against the Russian Federation:

Post 1:  EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – AN OVERVIEW
Post 2:  EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – MARCH 2022
Post 3: EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – APRIL & JUNE 2022
Post 4: EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – CRIMINALIZATION OF SANCTION VIOLATIONS

POST 5: LUXURY GOODS

The European Commission has imposed a number of restrictive measures against the Russian Federation in response to Russian aggression against Ukraine that began in February 2022. Among other measures, on March 11, the EU has imposed a ban on the export of luxury goods to Russia by the Regulation (EU) 2022/428, amending the Regulation (EU) No 833/2014.

In particular, Article 3(h) of the Regulation prohibits the sale, supply, transfer, or export, directly or indirectly, of luxury goods with a value exceeding 300 EUR per item to any natural or legal person, entity, or body in Russia or for sale in Russia. The measure includes a large variety of luxury goods, including cars, jewelry, clothes, watches, accessories, and products for domestic use. The full list of all luxury goods is included in Annex XVIII of the Regulations.

The sanctions, as set forth in the Regulation (EU) No 833/2014, do not extend to the transfer of goods within the territory of the European Union, or to any national of a member state, or to any legal person incorporated or constituted under the law of a member state, irrespective of where that person is. However, EU nationals and companies are prohibited from providing luxury goods for use in Russia, even if those goods have already been imported into the country. The prohibition also relates to goods originating from non-European countries but are transported through the EU.

Customs authorities of the EU member states are responsible for implementation and enforcement of the measures. Assessment of the value of a good in light of the 300 EUR limit is based on the statistical value of the good in regards to the price to be paid for the exported goods in accordance with the Commission Implementing Regulation (EU) 2020/1197. VAT is therefore not included in the statistical value.

Those providing information to the customs authorities are responsible for its accuracy and completeness. Customs authorities may demand supplementary information or documentation, such as invoices to verify the information provided in customs declaration forms.

The ban includes an exception for goods used by diplomatic and consular missions of member states or partner countries and of international organizations or their staff who are located in Russia. In addition, an exception has been made for the transfer and export of cultural goods to Russia as set forth by ongoing bilateral and multilateral cultural cooperation agreements.

Post 6: EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – TRANSFERABLE SECURITIES

Post 7: EU SANCTIONS AGAINST THE RUSSIAN FEDERATION – JULY 2022 PACKAGE

**Our series of articles on EU restrictive measures are provided for information purposes only and do not constitute legal advice. For professional advice tailored to your particular case, please contact us at: .**