The EU Member States today reached an agreement on the 11th sanctions package in the Committee of Permanent Representatives (COREPER). The Council will soon adopt the package in a written procedure; it will enter into force immediately after. By introducing this package, the EU is strengthening its toolbox so that it can take more consistent action against the circumvention of sanctions.
Robert Habeck, the Federal Minister for Economic Affairs and Climate Action, said, “The evasion of sanctions is unacceptable. We need to take decisive action against it. To this end, I presented proposals in February, and the 11th package of sanctions, which was adopted today, incorporates key elements of my proposals. Through the new package of measures, we can take better and more effective action against sanctions evasion across the EU. This reaffirms our resolve and unity in the EU against Russia’s illegal war of aggression. The task now is to rigorously implement the measures in the 11th package.”
The core of the 11th sanctions package is formed by a set of measures against the evasion of sanctions via third countries. The intention is to cooperate even more closely with the third countries involved and to take joint action against the circumvention of sanctions. The sanctions package also provides further options for action: it is possible to take measures against individual companies in third countries and to also impose export restrictions on third countries. These export restrictions on individual and particularly critical goods to third countries come into consideration if all other efforts remain unsuccessful.
The proposal that companies be obligated to report their own violations has now also been taken up and introduced for the area of trade-related prohibitions of the embargo on Russia. This means that everyone has a general obligation to disclose information. Anyone who has information relevant to sanctions must report it to the sanctions enforcement authorities. This is important because passing on tips and information is a decisive component in effectively tackling the evasion of sanctions.

Furthermore, the transit of critical goods to third countries via Russia will also be further restricted. In future, the transit prohibition will take effect not only for dual use goods, but also for advanced technology. Such goods could serve to strengthen Russia’s military and its technological capabilities. Transit via Russia bears particularly high risks of circumvention. The prohibition of particularly critical goods like these is therefore an essential measure.
Another important change in the 11th package of sanctions concerns the ban on the import of oil. The exception to the continued purchase of Russian pipeline oil no longer applies to Poland and Germany. This means that the efforts already made in Germany since the beginning of the year are now being backed up in the legal provisions. Germany has not purchased any Russian oil since the beginning of 2023, including via pipelines. The market has successfully established its independence and found alternative sources of supply. It was therefore only logical to follow this up with legally binding sanctions.
An overview of the anti-circumvention measures in 11th sanctions package can be found here.