If your company exports goods to Russia or Belarus — or has been considering it — you have almost certainly had to ask yourself at some point: is my product sanctioned or not? And if so, since when?
Since February 2022, the European Union has adopted an extensive and continuously expanding set of restrictive measures in response to Russia’s invasion of Ukraine. For European exporters, navigating this framework has become one of the most complex compliance challenges of the past decade.
This post is written specifically for companies that export or plan to export goods from the EU to Russia or Belarus. Its purpose is to explain what the sanctions are, how they have evolved, and how to check whether a specific product is affected.
Before going any further, it is important to be clear about what this post does not cover. The EU sanctions framework is extremely broad, and the vast majority of its provisions fall outside the scope of what is relevant to exporters of goods. The following are therefore deliberately excluded from this guide:
- Sanctions against specific individuals, oligarchs, or Russian and Belarusian entities
- Banking and financial sanctions (including the SWIFT ban and Central Bank restrictions)
- Restrictions on Russian state media broadcasting
- Airspace and overflight restrictions for Russian aircraft
- Port access restrictions for Russian-flagged vessels
- Cryptocurrency and payment system restrictions
- Financial limitations on EU citizens operating in Russia
What remains — and what this post focuses on exclusively — is the prohibition on exporting certain goods and technologies from the EU to Russia and Belarus.
The Legal Backbone: Regulation (EU) 833/2014
To understand how the current sanctions work, it helps to know where they come from.
The foundation is Council Regulation (EU) No 833/2014, originally adopted on 31 July 2014 in response to Russia’s annexation of Crimea and the destabilisation of eastern Ukraine. At that stage, the regulation was relatively limited in scope, targeting mainly dual-use goods and specific energy sector technologies.
What makes Regulation 833/2014 so central is that every subsequent package of sanctions has taken the form of an amendment to this same regulation. Rather than creating new legal instruments each time, the EU has progressively expanded the lists of prohibited goods by adding new annexes and extending existing ones. As of January 2026, the regulation has been amended over 40 times, and its annexes now run to thousands of pages.
For Belarus, a parallel but separate legal framework applies: Council Regulation (EC) No 765/2006, which has been similarly expanded since 2022. In practice, the export restrictions on goods to Belarus closely mirror those applicable to Russia, and the same approach to checking whether a product is sanctioned applies to both.
How the Sanctions Have Grown: A Timeline of Key Packages
The following is a summary of the main developments affecting exports of goods — not a complete list of every regulatory amendment, but a roadmap of how the restrictions have escalated since 2022.
February–March 2022 — The initial wave
Within days of the invasion, the EU introduced the first significant export restrictions. Regulation 2022/328 prohibited the export of dual-use goods and technology, goods that could contribute to Russia’s defence and security sector, equipment for oil refining, and goods for the aviation and space industry. Simultaneously, Regulation 2022/355 extended equivalent restrictions to Belarus, adding bans on wood, cement, iron, steel, rubber and specific machinery.
April 2022 — The pivotal expansion
Regulation 2022/576 was a turning point. It introduced Annex XXIII — a new annex listing an extremely broad range of industrial products whose export to Russia was prohibited on the grounds that they could contribute to the enhancement of Russia’s industrial capacities. This was the moment when sanctions moved well beyond dual-use and strategic sectors and began affecting a very wide range of standard industrial goods.
June–July 2022 — Sixth and seventh packages
Regulation 2022/879 extended the list of controlled chemical substances. Regulation 2022/1269 further expanded the list of items contributing to Russia’s military and technological enhancement, and introduced a ban on the export of gold.
October 2022 — Seventh package
Regulation 2022/1904 significantly extended Annex XXIII again, adding more product categories including goods for the aviation sector and extending import bans. This package also introduced a ban on the export of firearms and ammunition.
December 2022 — Eighth package
Regulation 2022/2474 added drone engines, electronic components, cameras, laptops, hard drives, IT components, night-vision equipment, generators and radio-navigation devices to the list of restricted goods.
February 2023 — Ninth package
Regulation 2023/427 extended the list further to include rare earths and compounds, electronic integrated circuits and thermographic cameras, among others.
June 2023 — Tenth package
Regulation 2023/1214 added electronic components, semiconductor materials, optical components, navigational instruments, metals used in the defence sector and marine equipment. It also introduced anti-circumvention measures, including restrictions on the transit of sanctioned goods through Russia.
December 2023 — Eleventh package
Regulation 2023/2878 added thermostats, DC motors and servomotors for drones, machine tools, machinery parts, lithium batteries and chemicals. It also introduced a ban on diamonds originating in Russia.
February–June 2024 — Twelfth and thirteenth packages
Regulation 2024/576 and subsequent amendments added UAV components, further industrial goods, and introduced restrictions on LNG projects and maritime transport services. A ban on the export of enterprise management and industrial design software was also introduced.
2025 — Fourteenth, fifteenth and sixteenth packages
Three further packages adopted in 2025 (Regulations 2025/395, 2025/932, 2025/1494 and 2025/2033) continued expanding the lists of restricted goods, adding further common high priority items — goods identified as frequently found in Russian weapons systems captured in Ukraine — as well as additional electronic components, industrial machinery parts, and chemical precursors. Regulation 2025/2618 (December 2025), the sixteenth package, introduced further expansions shortly before the current consolidated version entered into force on 16 January 2026.
Which Types of Products Are Affected?
Without listing specific HS codes, the following broad categories are subject to export restrictions to Russia under the current consolidated regulation:
- Dual-use goods and technology
- Goods and technology contributing to Russia’s defence and security sector
- Aviation and space industry equipment and technology
- Oil and gas sector equipment and technology
- A very wide range of industrial goods (machinery, electronics, components, tools)
- Luxury goods
- Firearms, parts, components and ammunition
- Specific chemical substances and precursors
- Common high priority items (electronic components identified in Russian military systems)
- Enterprise management software and industrial design software
The sheer breadth of Annex XXIII — the annex covering industrial goods — means that many products which would not intuitively seem “strategic” are in fact sanctioned. Exporters of industrial machinery, electronic components, measurement instruments, tools, sensors, motors and many other categories should not assume their products are unaffected without verification.
How to Check Whether Your Product Is Sanctioned
The most reliable method is to consult the consolidated version of Regulation (EU) 833/2014 directly. This single document incorporates all amendments and is the authoritative reference for determining whether a product is subject to export restrictions.
The version currently in force is dated 16 January 2026 and is available here:
🔗 Council Regulation (EU) 833/2014 — Consolidated text, 16 January 2026
On that same EUR-Lex page, you will always find a link to any more recent consolidated version, should further amendments be adopted after this date. This means the page remains a reliable entry point regardless of when you consult it.
The practical method is to open the document and search for the first digits of your product’s HS or CN code. If the code appears in any of the following annexes, the product is subject to export restrictions:
- Annex II — Energy sector goods (Article 3)
- Annex VII — Dual-use chemical precursors (Article 2aa)
- Annex X — Oil refining goods and technology (Article 3b)
- Annex XI — Aviation and space industry (Article 3c)
- Annex XVIII — Luxury goods (Article 3i)
- Annex XX — Additional aviation goods (Article 3k)
- Annex XXIII — Industrial goods contributing to Russian industrial capacities (Article 3l) — the largest and most relevant annex for most exporters
- Annex XXXV — Firearms, parts, components and ammunition (Article 3r)
- Annex XL — Common high priority items (Article 3v)
A few important caveats apply. First, some HS codes appear in multiple annexes with different conditions, end-use restrictions or exceptions — finding the code is the beginning of the analysis, not the end. Second, the interpretation of some provisions is not always straightforward, particularly where end-use or end-user conditions are involved. Third, the list continues to evolve, and what is permitted today may become restricted with the next package.
When in doubt, professional verification is strongly recommended. Contact us to assess whether your specific product is subject to sanctions before proceeding with any export.
Conclusion
Since February 2022, the EU’s export restrictions on goods to Russia and Belarus have grown from a targeted set of dual-use and strategic sector controls into one of the most extensive export sanction regimes ever imposed by the Union. Thousands of HS codes are now affected across a wide range of industrial, technological and consumer categories.
For any company that exports — or is considering exporting — goods to Russia or Belarus, product-by-product verification is not optional: it is a legal obligation. The consolidated regulation is the most reliable single reference, but reading it correctly requires care and, in many cases, expert guidance.