Home /
Actions /
2022-02-25-eu-council-regulation-328-dual-use-oil-refining-aviation-export-ban-russia [3]Policy↑ Trade↓ Market— single typed policy action — the spine's centre of gravity EU Council Regulation 2022/328 — dual-use, oil-refining and aviation export ban on Russia
Export control↓ Restrictive🇪🇺 EU · Council of the European Union✎ 2026-10-02
announced 25 Feb 2022
effective 26 Feb 2022
Status
in force since 26 Feb 2022
Sourcing
🟢 primary-OJ 1 primary
The EU issued this export control measure targeting 1 jurisdiction, touching dual-use-technology, oil-refining, aviation and 1 more sectors. It reads as restrictive.
RBI 2quant 3 · $50B📌 stable
On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.
Analyst notesShowHide
Mechanism
First EU trade-restriction package filed the day after the 24 February 2022 invasion. Builds on the existing Regulation 833/2014 Russia sanctions regime (in place since the 2014 Crimea annexation) rather than creating a new legal base. Three product classes are added to the export-ban annexes: (1) dual-use goods/technology covered by the EU dual-use list (Regulation (EU) 2021/821), including nuclear-related (uranium/thorium) dual-use items captured in the GTA HS-code mapping for this act; (2) goods and technology "suited for use in the oil refining industry"; (3) goods, technology and related services for the aviation and space industry. All three carry accompanying bans on technical assistance, brokering services, and financing/financial assistance.
Downstream implications
- Oil-refining equipment ban foreshadows the deeper energy-sector measures
of later packages (5th package coal ban, 6th package oil embargo — both already in the register).
- Aviation ban is the opening move against Russian carriers' access to
Western-built aircraft, parts and MRO/insurance services — a chokepoint that compounds over time as the existing fleet cannibalises for spares.
- Dual-use ban is the broadest net: it covers nuclear, electronics,
telecom and other listed categories in one shot rather than a sector-by-sector rollout.
Open questions
- Exact HS-code annex boundaries for the oil-refining and aviation
carve-outs were not independently re-derived from the OJ text for this filing (EUR-Lex full-text fetch was unavailable); GTA's state-act description was used to confirm scope at the categorical level.