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EU-Russia Sanctions: What are the penalties for air, road, and sea transportation?

What do sanctions in the aviation sector mean?

All Russian aircraft are banned from overflying EU airspace

In February 2022, the EU refused access to EU airports for Russian carriers of all kinds and banned them from overflying EU airspace. This means that airplanes registered in Russia or elsewhere and leased or rented to a Russian citizen or entity cannot land at any EU airports and cannot fly over EU countries. Private aircraft, e.g. private business jets, are included in the ban.

In addition, the EU banned the export to Russia of goods and technology in the aviation and space industry.

Insurance services, maintenance services and technical assistance related to these goods and technology are also prohibited. The United States, Canada and the United Kingdom imposed similar restrictions.

This means that Russian airlines cannot buy any aircraft, spare parts or equipment for their fleet and cannot perform the necessary repairs or technical inspections. As three-quarters of Russia’s current commercial air fleet were produced in the EU, the US or Canada, over time the ban is likely to result in the grounding of a significant proportion of the Russian civil aviation fleet, even for domestic flights.

What are the sanctions on road transport?

The EU has prohibited Russian and Belarusian road transport operators from entering the EU, including for goods in transit.

This sanction aims to restrict Russian industry’s capacity to acquire key goods and to disrupt road trade both to and from Russia. However, EU countries can grant derogations for:

  • the transport of energy

  • the transport of pharmaceutical, medical, agricultural and food products

  • humanitarian aid purposes

  • transport related to the functioning of diplomatic and consular representations of the EU and its countries in Russia, or of international organisations in Russia which enjoy immunities in accordance with international law

  • the transfer or export to Russia of cultural goods on loan in the context of formal cultural cooperation with Russia

The ban does not affect mail services and goods in transit between Kaliningrad Oblast and Russia.

What are the sanctions on maritime transport?

The EU has closed its ports to Russia's entire merchant fleet of over 2 800 vessels. However, the measure does not affect vessels carrying:

  • energy

  • pharmaceutical, medical, agricultural and food products

  • humanitarian aid

  • nuclear fuel and other goods necessary for the functioning of civil nuclear capabilities

  • coal (until 10 August 2022, after which imports of coal into the EU will be banned)

The measure also does not affect vessels in need of assistance seeking a place of refuge, or vessels making an emergency port call for reasons of maritime safety or saving life at sea.

The ban will also apply to vessels that try to evade the sanctions by changing their Russian flag or registration to that of another state. Port authorities can identify an attempt to reflag or change registration by checking a vessel’s IMO number (the unique identification number assigned on behalf of the International Maritime Organization).

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