Following several months of delay, largely attributable to political deadlock within the Council—including resistance from certain Member States in relation to the scope and economic impact of further measures—the European Union has now adopted its 20th package of sanctions against Russia.
The package has been implemented through a series of legislative instruments, including, inter alia, Council Regulation (EU) 2026/506 amending Council Regulation (EU) No 833/2014 (the “EU Russia Regulation”), as well as corresponding Council Decisions and implementing measures updating existing listings frameworks.
As reflected in the Council and Commission communications, the package is characterised by a strong anti-circumvention focus, with measures targeting energy revenues, financial channels and trade flows, alongside additional protections for EU operators. In this context, maritime transport remains a central vector of enforcement, with the new measures further tightening controls on vessels, services and infrastructure connected to Russian trade.
Against this background, this note examines the principal developments affecting the maritime and shipping sectors, with a particular focus on the changes introduced to the existing framework and their practical implications for operators.
Further import bans
The 20th package introduces additional import restrictions through the expansion of Annex XXI to the EU Russia Regulation, by adding further CN codes covering a range of industrial and raw materials.
These include, inter alia, minerals and construction materials (such as gravel, stone and lime), metallurgical by-products (including slag and ash), chemicals (notably sodium and magnesium compounds), ammonia, as well as certain metals and semi-processed materials.
As a result of their inclusion in Annex XXI, these goods become subject to the restrictions set out in Article 3i, which prohibit the purchase, import or transfer, directly or indirectly, of such goods where they originate in or are exported from Russia as well as the usual ancillary restrictions, including the prohibition on the provision of technical assistance, brokering services, financing or financial assistance related to the import of such goods.
In line with previous amendments to Annex XXI, the Regulation provides for a wind-down period in respect of newly listed goods, allowing the execution of contracts concluded prior to the entry into force of the new measures, subject to the relevant deadlines set out in the Regulation.
Restrictions on gas condensates
Article 3m of the EU Russia Regulation, which prohibits the purchase, import or transfer of crude oil and petroleum products falling under CN code 2709 and 2710, together with related services, has been amended to extend its scope.
In particular, a new paragraph of the article now provides that, as of 1 January 2027, the above prohibitions will also apply to natural gas condensates falling under CN code 2709 00 10 from liquefied natural gas (LNG) production plants.
Also some of the amendments to article 3n of the EU Russia Regulation extend the scope of the existing prohibitions to natural gas condensates (CN code 2709 00 10) derived from LNG production plants.
As of 1 January 2027, such condensates will fall within the same regime applicable to Russian crude oil and petroleum products and will be subject to a ban on the provision of services — including technical assistance, brokering, financing, insurance and reinsurance — related to their transport or trade to third countries, and a corresponding prohibition on their sale, brokering or transport, including ship-to-ship transfers.
Oil Price Cap framework
Article 3n continues to constitute the core provision governing the EU’s implementation of the oil price cap regime, as developed in coordination with the G7 Price Cap Coalition.
As previously structured, the Article establishes a prohibition on the provision of maritime transport and related services for Russian crude oil and petroleum products to third countries coupled with an exception where such products are traded at or below the price cap.
The amendments do not alter the fundamental architecture of this mechanism. The price cap exception remains operative, including the associated compliance requirements (such as attestation and information flows along the supply chain).
However, the revised text introduces a structural development by providing that the Council may, upon coordination within the G7 and the Price Cap Coalition, decide on the application or limitation of the price cap-based exception.
This effectively transforms the price cap from a fixed compliance framework into a flexible regulatory tool, capable of being adjusted—or potentially withdrawn—in response to market conditions and enforcement considerations.
Sale of tankers
Article 3q has been significantly tightened, further restricting the sale and transfer of tanker vessels for the transport of crude oil and petroleum products listed in Annex XXV, with HS code ex 8901 20.
In particular, the previous derogation allowing competent authorities to authorise the sale or transfer of ownership of such tankers to Russian persons or for use in Russia has been removed. As a result, the prohibition is now absolute, with no possibility for Member State authorities to grant exemptions in this respect.
In addition, the regime applicable to the sale or transfer of ownership of such tankers to third countries has been considerably expanded.
EU operators selling or transferring ownership are now subject to enhanced due diligence obligations. In particular, they are required to:
- take appropriate and proportionate steps to identify and assess the risk of re-transfer to Russia or use in Russia, ensuring that such assessments are properly documented and kept up to date, and
- implement appropriate policies, controls and procedures to effectively mitigate and manage those risks.
The buyers from third countries shall provide the necessary information to enable EU operators to carry out an adequate due diligence.
In addition, the obligation to notify competent authorities of any sale or transfer of tanker vessels to third countries — together with detailed disclosure requirements regarding the parties involved, ownership structure and vessel identifiers — remains unchanged and continues to apply.
The key development lies instead in the introduction of additional downstream safeguards. Any sale or transfer to a third-country purchaser must now include a contractual clause expressly prohibiting any subsequent resale or transfer of the vessel to Russia or for use in Russia.
This obligation is designed to operate beyond the initial transaction. The third-country acquirer is required to undertake that it will replicate the same restriction in any further resale or transfer, and to ensure that equivalent contractual provisions are passed on in subsequent transactions.
Listed vessels
Further amendments concern Article 3s, which continues to target listed vessels subject to restrictive measures. The updated provisions expand the scope of designated vessels, with the listing of 46 additional vessels in the relevant Annex. At the same time, 11 vessels have been delisted reflecting a continued calibration of the EU’s approach to vessel listings.
Amendments to Article 3s also introduce a new, narrowly framed derogation in respect of ship recycling. Competent authorities may now authorise otherwise prohibited operations involving listed vessels where these are strictly necessary for the purpose of recycling and the operations in question are necessary
- For the vessel to proceed to her recycling facility;
- For any relevant activities of the recycling facility in relation to the vessel, or
- For payments related to the recycling.
LNG and LGN Tankers
Further targeted measures have been introduced in relation to LNG infrastructure and specialised vessels.
A new Article 3rb establishes, as of 1 January 2027, a prohibition on the provision of LNG terminal services — whether directly or indirectly — to any natural or legal person in Russia, as well as to entities established in the Union that are more than 50% owned or otherwise controlled by Russian persons. In addition, operators will be prohibited from maintaining existing contracts for such services beyond that date. This marks a significant expansion of restrictions into midstream LNG infrastructure, capturing not only Russian counterparties but also EU-established entities under Russian control.
In parallel, newly introduced Article 3sa extends restrictions to certain categories of vessels, notably ice-breakers (with CN Code 8906 90) and LNG tankers (with CN code ex 8901 20), where these are registered under the Russian flag, certified by the Russian Maritime Register of Shipping, or owned or controlled by Russian persons. In such cases, it is prohibited to provide technical assistance, brokering services, financing or financial assistance related to those vessels.
The provision applies immediately to vessels with a clear Russian nexus, while its application to other LNG tanker vessels operating in or for use in Russia is deferred until 1 January 2027. Limited carve-outs remain, including for vessels in distress, emergency port calls, or operations necessary to safeguard human life or the environment.
Port transaction ban
Further adjustments have been introduced to the port transaction ban under Article 5ae, through amendments to Annex XLVII. The list of restricted ports has been expanded to include two additional Russian ports — Murmansk and Tuapse — as well as a non-Russian terminal, namely the Karimun Oil Terminal in Indonesia.
At the same time, a specific derogation has been introduced in relation to the port of Tuapse. In addition to the already existing, more general exemptions under Article 5ae, this carve-out permits certain transactions connected with that port where they concern specified categories of goods, including ferro-alloys and other alloys.
Overall, the package reflects a continued tightening of the existing framework rather than a structural shift. The focus is clearly on closing loopholes in the maritime and energy sectors, expanding the scope of existing restrictions and strengthening anti-circumvention tools, including through downstream contractual obligations.
At the same time, the introduction of targeted derogations confirms a pragmatic approach, preserving limited flexibility where necessary without undermining the broader regime.
From a practical perspective, operators should reassess compliance processes, particularly in relation to counterparties, vessel exposure and contractual safeguards.
Should you require any further information or assistance in assessing the impact of these measures, please do not hesitate to get in touch.