Can You Still Export to Russia Through a Third Country?

When the first EU sanctions packages were introduced in early 2022, we assumed it was only a matter of time before companies started asking us to help manage exports to Russia routed through EAEU member states. We made a deliberate decision from the outset not to get involved in any operation of that kind. What surprised us over the following years was how little demand there actually was: in four years, a single company approached us with that kind of request, and it was straightforward to explain why we could not help. The reason is practical rather than moral. Whoever triangulates goods has ways of doing so that do not require formal certification from an agency like ours. The documentation we produce is for products entering a market legally, not for goods travelling through jurisdictions they are not supposed to reach. For that kind of operation, we are simply not useful.

The question itself, though, is one we still hear regularly from exporters thinking through their options in good faith. It deserves a clear answer.

Triangulating goods benefits Russia at high risk for the exporter

The commercial logic behind triangulation looks simple on paper: route goods through a third country, and they reach a market that would otherwise be closed. The problem is who bears the risk in that arrangement. Russia receives the goods it needs. The exporter, if something goes wrong, has no legal ground to stand on anywhere.

Even in cases where a triangulated shipment reaches its final destination without incident, the exporter’s position is structurally exposed:

• No legal protection in any jurisdiction: neither the country of export nor the final destination recognises the transaction as legitimate
• Direct exposure to EU sanctions law, which since 2024 treats deliberate circumvention as a criminal offence in several member states
• No contractual recourse in cases of non-payment, disputed delivery or seized goods
• Dependence on intermediaries in opaque jurisdictions, operating under arrangements that are not enforceable in any court
• Active monitoring by OLAF and national customs authorities, which track trade flows through known transit countries and have already dismantled schemes involving hundreds of shipments and tens of millions of euros

The EU’s 20th sanctions package, adopted in April 2026, made the direction of travel explicit. For the first time, the EU activated its anti-circumvention instrument directly against a third country, prohibiting exports of specific goods to Kyrgyzstan to prevent their re-export to Russia. Kyrgyzstan is the first country named under this mechanism. The instrument exists precisely to be used again.

The numbers put it in perspective

EU exports to Russia fell from around €8 billion per month in February 2022 to roughly half that figure a year later, and have continued declining. Russia’s share of extra-EU exports dropped from 3.8% to 1.4% between February 2022 and late 2023, according to Eurostat. The cumulative contraction runs into hundreds of billions of euros.

Against that scale, the total exports from Kyrgyzstan to Russia in 2025 amounted to $493 million, of which machinery, electronics and optical equipment account for under $200 million, according to UN COMTRADE data. That figure includes entirely legitimate trade. Triangulation exists, but its measurable contribution to filling the gap left by Western sanctions is marginal, because the intermediary countries do not have the logistical and financial capacity to absorb and redistribute volumes of that magnitude.

Russia is also closing the certification route

There is a second form of triangulation that receives less attention: the certification route. Here the logic runs in the opposite direction. Goods triangulated through third countries serve Russian interests, because Russia receives products it could not otherwise import. EAC certification obtained through third countries works against Russian interests, because it reduces Moscow’s control over what enters its market and how it is documented.

An EAC certificate issued in Kyrgyzstan by an intermediary body for a foreign manufacturer who cannot operate through Russian channels directly is exactly the type of document that Russian customs authorities have started to scrutinise and, in a growing number of cases, reject at the border. The consequences for exporters who have relied on that route are serious: a blocked EAC certificate at Russian customs means a shipment that cannot clear, with no clean legal path forward.

Where the real opportunities are

Kazakhstan and Uzbekistan are growing markets with genuine import demand, active infrastructure investment and no export restrictions from the EU. Both attract interest from European manufacturers precisely because there are no geopolitical tensions around the export and certification process: the rules are clear, the framework is stable, and the paperwork does not carry the risks that Russia-bound documentation does today. The full picture of what exporting to Kazakhstan and Uzbekistan involves is covered in our dedicated guide.

If your company is evaluating export options in the post-Soviet space, contact us to assess which markets make sense for your product and what the certification path looks like.