AUTHOR: Anna Cesar – Senior Manager Regulatory Compliance, EMEA

On 18 July 2025, the European Union (EU) Council adopted its 18^th sanctions package against Russia, one of the most comprehensive measures to date. The package introduces significant new measures and updates across the energy, financial, and defence sectors.

¿Por qué es importante?

A key objective of the new sanctions is to tighten export controls on goods with potential defence applications, particularly in the technology and industrial sectors.

Impacts on the Clinical Supply Chain
Under the expanded scope of Article 3k, the following items are now restricted:

• Temperature loggers
  • Now covering all articles under Heading 9025 of the Harmonized System
  • Applies regardless of technology type (GPS-enabled or not)
  • Impact: Any shipment of temperature loggers to Russia or Belarus now requires an export authorization.
• Articles of plastic (HS 3926 90)
  • Includes bag ties, cryovials, pipettes, and other common patient kit components

A grace period runs until 21 October 2025, allowing businesses to fulfil existing obligations or secure the necessary authorizations before prohibitions take effect.

Additional Measures

Stricter anti-circumvention rules have been introduced. Member state authorization is now required for exports of technology goods (Annex VII) if there is reasonable cause to suspect they may be indirectly re-exported to Russia or Russian entities.

Exporters are strongly encouraged to perform due diligence to ensure export transactions comply with EU sanctions. 

Service reliability remains our highest priority. Marken is dedicated to assisting clients in adapting to evolving regulatory and trade environments. For further information or inquiries, please contact our team at TradeCompliance@marken.com.

Fuentes:

https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1840
 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202501494