Embargos

Draft - Page is currently being revised!

Embargoes are imposed for foreign or security policy reasons and restrict the freedom of foreign trade with certain countries.

Shipping goods to embargoed countries

The export of dual-use goods (both civilian and military) to embargoed countries is prohibited if the goods are or could be intended in whole or in part for military purposes or military end users.

The export of dual-use goods for non-military purposes is subject to authorisation. Licences must be applied for individually at the BAFA (Federal Office for Economics and Exports) for each export and require a long lead time due to long processing times at the BAFA. The goods list check must therefore be carried out as early as possible in the event of an embargo.

Import ban for listed goods from embargoed countries

The import, acquisition and transport of goods listed in the ‘Export List - Section A’ (goods originally designed for military purposes) from the following countries, regardless of whether the goods originate in these countries, is prohibited in accordance with Section 77 AWV:

Democratic People's Republic of Korea,
Eritrea,
Iran,
Libya,
Syria,
Russia.

Sanctions against Russia

The first EU sanctions against Russia came into force on 23 February 2022 in connection with the war in Ukraine. Since then, they have been gradually expanded and strengthened:

Chronological overview of EU sanctions against Russia

No-Russia clause in contracts

The so-called ‘No-Russia clause’ obliges companies to contractually prohibit the repurchase of certain goods to Russia. Article 12g of EU Regulation 833/2014 requires companies to include a clause in their contracts for the sale, delivery, transfer or export of goods and technologies to third countries that contractually prohibits re-import to Russia. This is intended to prevent sanctions from being circumvented via third countries.

Such clauses are not necessary if the sale is to one of the partner countries listed in Annex VIII of Regulation 833/2014.

These are currently: