Regulatory Compliance updates May 2024

May 30, 2024

Baltics, Poland, & Finland agree on uniform implementation of EU Russia sanctions & export controls

On 9 May 2024, the Heads of the Customs authorities of five European Union Member States, i.e. Lithuania, Latvia, Estonia, Poland and Finland, signed in Vilnius an Agreement on the application of uniform controls for the implementation of sanctions.

On January 26 of this year, the Heads of the Customs authorities of Lithuania, Latvia and Estonia approved the regional approach (Agreement) of the Baltic States on the application in Estonia, Latvia and Lithuania of uniform controls to the implementation of sanctions. May 9th, this Agreement has been expanded further in the region. The customs authorities of the signatory countries will strengthen controls on goods subject to export prohibitions and restrictions, and will apply such common measures, as, for example, requiring the submission to the Customs authorities of a document or information, called the manufacturer’s declaration, issued by the manufacturer of the exported or re-exported goods. The Customs authorities will also require other documents preventing the possibility of the entry of goods to Russia or other probabilities of circumvention of sanctions.

Denmark introduces packaging EPR 

The Packaging Directive mandates that all EU member states implement an Extended Producer Responsibility (EPR) for packaging by 2025. Denmark is the final country to introduce and enforce packaging regulations. These regulations, which apply to all producers under the EPR, will take effect starting January 1, 2025.

EU extends trade support to Ukraine for one more year 

The suspension of import duties and quotas on Ukrainian exports to the European Union will be extended for another year, following today's adoption by the Council and April 23 vote in the European Parliament. The EU is thereby delivering once again on its commitment to support Ukraine for as long as it takes. These so-called Autonomous Trade Measures (ATMs) have been in place since June 2022 and are a key pillar of the EU's unwavering support for Ukraine, providing a lifeline to the country's economy through access to the EU market.

The measures are also mindful of EU stakeholders' concerns. To this end - and considering a significant increase in imports of some agricultural products from Ukraine to the EU in 2022 and 2023 - the renewed ATMs contain a reinforced safeguard mechanism. It allows for quick remedial action to be taken in case of significant disruptions to the EU market or the markets of one or more Member States. In addition, an emergency brake applies to eggs, poultry, sugar, oats, maize, groats, and honey, which will be automatically triggered if import volumes reach the average yearly imports recorded between 1 July 2021 and 31 December 2023. Today, the Commission's Directorate-General for Trade has also published those import volumes. Now that the ATMs are adopted, the Commission is also taking the necessary steps, through consultations with Ukraine under Article 29 of the EU-Ukraine Association Agreement, to agree on longer term reciprocal tariff liberalisation. This process aims to provide economic certainty and a stable framework for trade to both Ukraine and the EU, as well as to farmers and businesses. This would also represent an important step forward for Ukraine's reconstruction and further integration into the EU internal market, with the ultimate goal of securing the country's future accession to the Union.

Next steps : The new ATMs will enter into force on 6 June, after the current regime expires on 5 June 2024. They will be in effect until 5 June 2025.

EU Import Control System 2 - Release 3

Economic operators carrying goods by sea, inland waterways, road and rail will have to submit a complete Entry Summary Declaration (ENS) dataset to ICS2. This includes postal and express carriers who transport goods using these modes of transport as well as other parties, such as logistic providers issuing transport documents to their clients, and in certain circumstances also final consignees established in the EU, will have to submit ENS data to ICS2. ICS2 Release 3 goes live on 3 June 2024.  

EU broadens Iran restrictive measures

The EU have broadened the framework for its Iran sanctions for Iran’s military support for Russia. Sanctions will now cover missiles as well as UAVs, and people and entities supplying, selling or otherwise being involved in transferring Iran’s missiles and UAVs. Link

EU Commission updates Russia sanctions FAQs on Donetsk, Luhansk etc, & on iron & steel partner countries

The EU Commission has added to its Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts FAQs that “considering the fluid situation, a dynamic assessment of this control [of which areas of the Ukrainian oblasts of Donetsk, Kherson, Luhansk, and Zaporizhzhia are subject to restrictions] could be necessary. The EU Commission has amended its Import, Purchase & Transfer Of Listed Goods FAQs to reflect the addition in February 2024 of the UK as a partner country to import controls on Russian iron and steel. Link  and Link

EU publishes directive criminalising sanctions violations

The EU has published in the official journal the directive criminalising sanctions violations. The directive will enter into force on the 19 May 2024. Member states will then have 12 months to incorporate the provisions of the directive into their national legislation. Link

European Union implementation of the packaging regulation 

On Wednesday, April 24, 2024, the European parliament adopted the PPWR – The Packaging and Packaging Waste Regulation. Effective at once, the Regulations come into effect in the European Union. The PPWR is implemented with one general goal: all packaging on the European market is to be reusable or recyclable by 2030. Prevention of packaging and the increase in the quality of recycled materials are measures implemented to achieve this goal for all types of packaging. The EU and Japan aim to coordinate and advance their efforts to address strategic dependencies and systemic vulnerabilities in global supply chains by improving their resilience and reliability, particularly in the context of addressing risks related to non-market economies and unfair competition. They pledged to work closely together on climate change, energy security, cyber security and stability of supply, based on jointly agreed principles.  The EU and Japan stressed the importance of enhancing their cooperation on economic security. They reiterated the essential role of the international rules-based trading system in underpinning the stability of global trade.

Malta publish guidance on Article 5r of Regulation 833/2014

The Maltese Sanctions Monitoring Board have published guidance on the reporting obligations and deadlines under Article 5r of Regulation. The guidance applies to:

  • Legal persons, entities and bodies established in the Union whose proprietary rights are directly or indirectly owned for more than 40 % by a legal person, entity or body established in Russia; a Russian national; or a natural person residing in Russia and;
  • Credit and financial institutions.

Türkiye stops all trade with Israel

Türkiye’s Ministry of Trade has announced that "export and import transactions related to Israel have been stopped, covering all products” and Türkiye “will strictly and decisively implement these new measures until the Israeli Government allows an uninterrupted and sufficient flow of humanitarian aid to Gaza”. Link

UK Export Controls and Licensing: “NTE 2024/09: update on AUKUS”

AUKUS is a trilateral defence partnership between Australia, the UK and the US which was announced in September 2021. It consists of 2 pillars and has been designed to allow the 3 nations to cooperate closely on defence capabilities. These capabilities include submarine technology and cutting-edge advanced features such as artificial intelligence and quantum technologies. To help deliver the AUKUS Partnership, the AUKUS nations have agreed to reform their export controls to support, to the maximum extent possible licence free trade between and amongst the nations. The UK will introduce reciprocal arrangements through an AUKUS specific open general licence (OGL) that will cover the equivalent range of goods and technology on the US and Australian exemption. A draft version of the UK’s OGL for the AUKUS Partnership is attached below. We would welcome comment on the draft up to 1 July 2024.

UK updates Russian import sanctions guidance

The UK has added Norway as a partner country for the iron & steel import sanctions and updated its monitoring and enforcement guidance on import sanctions on Russian diamonds and iron & steel. The monitoring and enforcement guidance encourages “all parts of the supply chain for third country processed imports to the UK to undertake the necessary due diligence to ensure that sanctions are not being circumvented directly or indirectly” and importers are “advised to include assurances that imports are not of Russian origin in contractual agreements”.

United Kingdom: Introduction of new trade sanctions against Belarus

The UK has introduced additional trade sanctions against Belarus. The ban on imports of goods consigned from or originating in Belarus have been extended to cover all commodity codes listed under Chapter 76. Limited exemptions may apply:

  • Goods with a DBT Import licence (9011)
  • Goods not subject to sanctions (9022)

Where an exemption does NOT require an import licence, please declare “9022”.

UK to proscribe Terrorgram as terrorist organization

A draft proscription order has been made against the Terrorgram collective in the UK Parliament. According to the UK Home Office, the Terrorgram collective is “an online network of neo-fascist terrorists who produce and disseminate violent propaganda to encourage those who consume its content to engage in terrorist activity”. Link

New UK legal services Russia general licence coming into effect on 29 April 2024

On 28 April 2024 General Licence INT/2023/3744968 will expire and on 29 April 2024 it will be replaced by a new legal services general licence: General Licence INT/2024/4671884. The notice contains 37 FAQs on changes in the new GL, the scope of the GL, fees, expenses, and hourly caps, reporting requirements, interaction of the GL with specific licences, and payment routes. Link

United Kingdom: Update to Import control of timber and timber products subject to the FLEGT licensing scheme

A new DEFRA footnote has been added to the Measure Type 747 - Import control of timber and timber products subject to the FLEGT licensing scheme as of 24 May 2024. Please see Footnote CD773 with the following description: Certificate C690 shall be declared for imports of timber products of Indonesia origin directly imported into the UK. Goods that are a) not part of the UK/Indonesia FLEGT Voluntary Partnership Agreement, b) not directly imported into UK from Indonesia; or c) are of a non-commercial nature are exempt from this measure. If exempt use Y057.


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