Russian Oil and Petroleum Products: mailbox sanctions oil contracts closes as of June 16, 2023

In June 2022 the European Union (EU) adopted a sixth package of sanctions that, among other things, prohibits the purchase, import and transfer of crude oil and certain petroleum products by sea from Russia to the EU. For the transition period until February 5, 2022, contracts could be sent to a special mailbox. This mailbox is now no longer necessary, and therefore it will be closed as of June 16, 2023.

These measures apply from December 5, 2022, to crude oil and from February 5, 2023, to refined petroleum products. As of February 5, 2023, the purchase, import and transfer of crude oil and refined petroleum products from Russia will be permanently banned, and ships carrying those products will also not be allowed to call at EU ports.

There are two situations where these sanctions do not come into play

These situations are:

1. crude oil and refined petroleum products with origin Kazakhstan
2. natural gas condensates with CN code 2709 00 10, coming from installations for the production of liquefied natural gas, originating in or exported from Russia

In these situations ships do come from Russian ports and appear to have sanctions goods on board. To make it clear to the Dutch Customs, coast guard and port authorities that these are exceptions, we ask for extra information in the ENS, in the goods description, in the situations below. This avoids unnecessary delays when entering Dutch ports.

1. Crude oil and refined petroleum products with origin Kazakhstan

Clearly state in the ENS in the goods description box that the origin is Kazakhstan. This makes it clear to the Dutch Customs that it is not sanctioned goods. Of course, when making the import declaration, you must prove that the origin is Kazakhstan through Certificates of Origin, and an investigation into that origin may take place.

2. Natural gas condensates with CN code 2709 00 10, coming from installations for the production of liquefied natural gas, originating in or exported from Russia

These goods are not subject to the import ban. However, the shipments must be notified to the RVO and those notifications eventually go to the European Commission. State in the ENS in the box goods description: Natural gas condensates with CN code 2709 00 10, coming from installations for the production of liquefied natural gas. This makes it clear to the Dutch Customs that these are not sanctioned goods. Of course, additional checks on the type of goods may take place upon importation.

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