On February 25, 2022, the Council of the European Union adopted Council Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine. The regulation entered into force on February 26, 2022.
The regulation imposed a blanket prohibition on the sale, supply, transfer, or export, directly or indirectly, of all dual-use goods and technology listed in Annex I of the EU Dual-Use Regulation (EU) 2021/821 to any natural or legal person, entity, or body in Russia, or for use in Russia, regardless of whether the goods or technology originated in the European Union. This replaced the prior regime, which had limited dual-use restrictions to items intended for military use or military end-users.
In addition to dual-use items, the regulation introduced a new Annex VII restricting the export of goods and technology that could contribute to Russia’s military and technological enhancement or to the development of the defense and security sector. This annex covered electronic components, semiconductors, sensors, lasers, navigation equipment, marine and aerospace technology items not normally subject to EU dual-use controls but corresponding to items on the U.S. Commerce Control List.
Related technical assistance, brokering services, financing, and financial assistance were also prohibited. Exemptions were available only under narrow conditions, including for humanitarian purposes and contracts concluded before February 26, 2022, subject to member state authorization. The measures represented the most extensive EU export control action to date and were subsequently mirrored in restrictions on Belarus adopted on March 2, 2022.