EU Council Regulation 2022/428 — 4th Russia sanctions package (iron and steel import ban, luxury-goods export ban, SOE transaction ban)

Mechanism

Regulation 2022/428 amends Regulation (EU) No 833/2014 in three trade-relevant ways (Articles 3g, 3h and 5aa as inserted):

• Iron and steel import ban (Art. 3g, Annex XVII). Prohibits importing into the Union

iron and steel products listed in Annex XVII (CN codes such as 7208 hot-rolled sheets and strips) that originate in or have been exported from Russia; also prohibits purchasing them where located in or originating from Russia, transporting them, and providing technical assistance, brokering, financing or insurance related to those activities. Contracts concluded before 16 March 2022 may be executed until 17 June 2022.

• Luxury-goods export ban (Art. 3h, Annex XVIII). Prohibits selling, supplying,

transferring or exporting Annex XVIII luxury goods to any person in Russia or for use in Russia, applying above EUR 300 per item unless the Annex specifies otherwise. Diplomatic-mission and staff personal-effects carve-outs apply.

• State-owned enterprise transactions (Art. 5aa, Annex XIX). Prohibits any transaction

with listed Russian entities that are publicly controlled or over 50% publicly owned, and with non-EU entities more than 50% owned by them. Wind-down until 15 May 2022 for pre-16 March contracts. Transactions strictly necessary for the purchase, import or transport of fossil fuels, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the Union are exempted (Art. 5aa(3)(a)).

The recitals also record the companion Council Decision (CFSP) 2022/430 measures: a ban on new investment in the Russian energy sector and on exports of goods and services for the energy industry (excluding nuclear and downstream energy transport), and a ban on credit rating services to Russian clients.

Downstream implications

• Steel is the first Russian metals product line the EU cut off by name; the exemption in

Art. 5aa(3)(a) keeps ore and non-ferrous metals (titanium, aluminium, copper, nickel, palladium, iron ore) flowing, so this measure does not remove those inputs.

• Russian semi-finished steel (slabs, hot-rolled coil) was a feedstock for EU re-rollers;

buyers had until 17 June 2022 to run off legacy contracts.

• Register-state note: the register holds no trade-value figure for the covered CN lines

from this source; scale is not quantified here.

Open questions

• Later packages widened Annex XVII; how the coverage of this first annex maps to the

currently in-force list is not established from this source.