Switzerland: Tenth EU Sanctions Package Alignment — Petroleum Products, Bitumen/Asphalt and Synthetic Rubber Import Ban

Mechanism

Switzerland's Russia sanctions regime operates by sequential Federal Council amendment of the Ukraine Ordinance (SR 946.231.176.72), tracking the EU's numbered sanctions packages with a lag — here the remainder of the EU's tenth package (adopted 25 February 2023) took effect in Switzerland on 29 March 2023. The operative change for economic exposure is the widening of the existing import ban's product scope: petroleum products beyond crude and refined fuels (petroleum jelly, petroleum coke), bitumen/asphalt and bituminous mastics (road-construction inputs), carbon, and synthetic rubber are now barred from Russian origin. The package also carried further export-control and entity-designation measures tied to Iran-linked drone-transfer concerns, consistent with the EU's own tenth-package Iran-drone designations.

Downstream implications

• Swiss-domiciled commodity traders lose a further tranche of Russian-origin

feedstock they could otherwise still lawfully handle — notably bitumen/ asphalt (road-construction input) and synthetic rubber.

• Road-construction and tyre/rubber-goods manufacturers sourcing

Russian-origin bitumen or synthetic rubber via Swiss intermediaries lose that channel once the grandfathering window closes.

• Entity designations tied to Iran-Russia drone transfers extend the

sanctions perimeter beyond Russian counterparties to Iranian suppliers.

Open questions

• Exact length of the grandfathering/transition period for each newly listed

product category was not confirmed from a source reachable within budget.

• Full list of newly designated entities (count, names) was not reproduced

in the primary press release.