EU warns against third country circumvention

On 1 April, the European Commission published a document (2022/C 145 I/01), which warned that, against the backdrop of tightening sanctions and export controls against Russia, ‘[E]conomic operators in the EU are advised to take adequate due diligence measures available in order to prevent circumvention of the measures — via exports to third countries from where such goods can be diverted easily towards Russia and Belarus.’

It said, ‘Particular attention has to be paid to exports of such goods to countries of the Eurasian Economic Union (EAEU, composed in addition to the Federation of Russia and the Republic of Belarus of the Republics of Armenia and Kazakhstan and of the Kyrgyz Republic), as goods in any member of the EAEU are in free circulation throughout the EAEU — through imports from third countries from where the goods concerned can be diverted easily to the EU, in particular when such countries do not apply restrictions on imports from Russia and Belarus; this is in particular the case of goods imported from other EAEU countries.’

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C:2022:145I:FULL&from=NL