Changes to regulations on export, transit and import of goods subject to EU sanctions following Russia’s aggression against Ukraine

12 February 2025 | Knowledge, News, Tax Focus, The Right Focus

On the occasion of another anniversary of Russia’s attack on Ukraine, the Polish legislature decided to tighten regulations on economic cooperation with Russia and its allies. The bill was signed into law on 6 February. We take a look at the changes and their potential impact.

What are the changes

The new regulations require individuals and entities exporting goods subject to EU restrictions to attach to customs declarations a declaration that the goods will not be used in a manner contrary to EU law.

The declaration must include information on the route of the goods, their destination and an assurance that they will not be resold or processed on the territory of Russia or Belarus. In addition, the person making the declaration must include a statement of awareness of criminal liability for making false statements.

If there is a risk of sanctions being circumvented by exporting goods to countries suspected of cooperating with Russia, or by transporting them through Russia or Belarus, the head of the customs and tax office may require the exporter to provide an additional declaration from the manufacturer of the goods confirming that the goods will not be used in a manner inconsistent with EU regulations.

Once the goods have left the EU, exporters must also provide customs clearance documents.

If violations are found, the heads of customs and tax offices have the right to seize the goods and request their forfeiture to the State Treasury. This also applies to sanctioned goods in transit through Russia and Belarus. A fine of up to PLN 500,000 may be imposed for failure to submit documents confirming customs clearance within the prescribed period.

In addition, the act introduces new provisions for the import of wood products classified under Chapter 44 of the Combined Nomenclature. To ensure compliance with EU sanctions, importers are required to provide evidence of the origin of the wood and details of the supplier or manufacturer. Violations of these provisions may also result in the seizure of goods and their forfeiture to the State Treasury.

16th package of sanctions against Russia

The European Commission has unveiled the 16th package of sanctions against Russia, which, as the Polish Minister for European Union Affairs pointed out, is expected to have a significant impact.

The new restrictions include a ban on aluminium imports from Russia and additional restrictions on the Russian financial sector. Oil tankers will also be subject to sanctions.

There are also plans to impose tariffs on other agricultural products and fertilisers from Russia and Belarus. These are only announcements at this stage, but we will keep you informed of further developments.

Summary

As a member of the European Union, Poland supports measures to prevent Russia from further escalating the conflict and destabilising the region. The tightening of economic regulations aims to increase control over trade in goods that could be used to circumvent EU sanctions.

The introduction of the obligation to provide detailed customs declarations and the severe penalties for violating this obligation are intended to maintain solidarity among EU countries in the fight against Russian aggression. These measures are an unequivocal condemnation of Russia’s actions and an expression of support for Ukraine’s sovereignty and its right to defend itself against an unprovoked war. Europe’s joint response, including the tightening of economic cooperation rules, aims to further reduce Russia’s ability to finance and support its war and to demonstrate that the international community will not tolerate law-breaking and military aggression.

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Jan Janukowicz

Jakub Dittmer

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Contact us:

Jan Janukowicz

Jan Janukowicz

Advocate Trainee / Associate / Tax Law

+48 736 272 203

j.janukowicz@kochanski.pl