EU import ban on petroleum products obtained from Russian-origin crude oil

The EU’s ban on the purchase, import or transfer of refined petroleum products derived from Russian-origin crude oil entered into force on 21st January 2026 (Article 3ma of Regulation 833/2014 and associated FAQs from October 2025):

Frequently asked questions on restrictions on import ban on refined products obtained from Russian crude oil concerning sanctions adopted following Russia’s military aggression against Ukraine

From 21st January 2026, it will be illegal to directly or indirectly purchase, import or transfer, directly or indirectly, petroleum products containing Russian crude oil from countries outside the EU. This affects imports and transfers into the EU. This does NOT affect the purchase, import into third countries or transfer by EU operators of such products to third countries, including transit through EU waters. 

Background

The ban formed part of the EU’s 18th sanctions package, and was subject to a lengthy implementation process in order to give EU operators time to adjust their trades/practices and implement internal controls to manage risks appropriately. 
The specific mischief that the EU is attempting to address is that under the EU sanctions that have been in place since 2022, Russia has been able to export crude oil to third countries such as India, Turkey and China. Much of that crude oil has found its way back into the EU, particularly from India and Turkey, in the form of refined petroleum products. This has been perceived as a gap in the sanctions framework as it has enabled Russia to export large amounts of crude. The UK has indicated that it too will ban petroleum products made from Russian crude in 2026 but has not given a date nor details.

Specifics

The ban is set out in Article 3ma of Regulation (EU) 833/2014 and covers the following: 

• Applies to petroleum products classified under CN 2710 where those products were derived from crude oil of Russian origin (CN 2709 00).
• Restrictions apply to purchase, import, or transfer of such products into the EU, even when performed by non EU operators if their activity contributes to importation into the EU. 

At the time of import, the importer must prove the country of origin of the crude oil used for refining in the product in countries outside the EU. This means that for all products under CN code 2710 imported from countries outside the EU, supporting documents of origin must be presented for the crude oil (with CN code 2709) contained in the petroleum product. 

The requirement to provide evidence of the country or origin does not apply if the product is imported from a partner country listed in Annex LI (see below).

Petroleum products imported from third countries which were net exporters of crude oil in the previous calendar year shall be considered to have been obtained from domestic crude oil and not from crude oil originating in Russia, unless a competent authority has reasonable grounds to believe that they have been obtained from Russian crude oil (see below).

Article 3ma includes a specific prohibition against providing, directly or indirectly, technical assistance, brokering services, financing or financial assistance, as well as insurance and re-insurance, related to the prohibition.

Impact

Compliance with the restriction is expected to happen at operational level, whereby EU customs authorities will need to be provided with “…relevant information necessary to identify the origin of the crude oil used in the production of the petroleum products, including appropriate evidence on the country where the crude oil used has been extracted”. However, involved EU persons need to be aware, so that they are not complicit with a breach through the express “related services” restriction.

Enhanced due diligence is required from operators with regards to shipments originating from Turkey, India and China. These countries are believed to have increased their imports of Russian crude oil since Russia’s full-scale invasion of Ukraine in February 2022, so the likelihood of importing refined products from those countries which are made from Russian-origin crude oil is therefore higher. 

Certain situations involve a lower burden:

• Import from partner countries listed in Annex LI (Canada, USA, Norway, UK, Switzerland, Australia, Japan and New Zealand). When refined products are imported from those partner countries no evidence needs to be provided on the origin of the crude oil from which the petroleum product is obtained.
• Imports from net exporters of crude oil (as determined annually), which benefit from a presumption that petroleum products of their non preferential origin were produced from domestic crude oil. A list of those countries is set out on pages 3 to 5 of the FAQ document.

Due Diligence Expectations

Operators are instructed to:

• Exercise enhanced due diligence when origin risk is higher (e.g., shipments from Turkey, India, China, or countries known to mix crude imports).
• Be cautious where documentation appears unreliable or where trading patterns raise suspicion.