The EU has implemented a new sanctions package against Russia to which Norway has joined. The background is Russia's war against Ukraine, contrary to international law. February the 24th marked one year since Russia carried out a full-scale invasion of Ukraine and 9 years since the beginning of Russia's illegal invasion and occupation of Ukrainian territory.
The new export restrictions focus on transport and logistics and all previous restrictions have also been continued. As the USA also has its restrictions, we also have to behave within the framework that they have provisions for. The idea behind the restrictions is that anything that might help Russia in their warfare is prohibited. The ban is interpreted very broadly by the authorities and therefore almost all types of goods are subjectable to the restrictions.
Transit by truck or train through Russia is also prohibited
Even if the shipment has a destination other than Russia or Belarus, redirection or forwarding will also be prohibited and we are obliged to catch such deviations. The restrictions therefore affect both exporters and transporters. For example, a large carrier recently received a hefty fine because a shipment they had, which was sent to France, eventually ended up in Russia after all. It did not help that the carrier was acting in good faith.
Since we also have a responsibility to ensure against forwarding to Russia or Belarus, our customers actually have to assess whether there is a risk of goods ending up in Russia. In such cases, it should be ensured that the recipient confirms that the goods will not be forwarded.
Sender's responsibility
FREJA will not ask our customers as long as we see that the goods have a place of delivery in the EU. We assume that this customer information is sufficient information so that you ensure that the shipments are not subject to restrictions. There are some recipient countries you should be particularly observant of and always ask the recipient that the goods are not going to Russia or Belarus. Examples of such countries are Georgia, Moldova, Turkey and others.
FREJA will also be extra vigilant if we receive shipments to such countries and reserve the right to ask. Also note that reactions to violations can result in extremely high fines/fees that can hit you directly or FREJA as the carrier. According to NSAB § 26, a reaction against us will result in a recourse claim against the customer who is behind the assignment. FREJA shall be held harmless.
Detailed rules on applying for licenses and on export restrictions can be found at these links:
Import and export restrictions against Russia and Belarus
You can also find more information about the EU's 10 sanctions package online.
Do not hesitate to contact us if you have any doubts or questions about these restrictions. FREJA will be very grateful for feedback on this topic and any tips that may be useful.