What changed
On 23 July 2026 the Council of the EU adopted the 21st sanctions package against Russia. It covers energy, transport, gold, finance (including crypto-assets), trade and the military-industrial complex.
On the trade side, new items were added to Annex XXI (the list of goods banned from import from Russia). According to law firm Baker McKenzie, these include ores of copper, nickel, lead and precious metals, unalloyed zinc, alkaline earth metals, zinc and chromium oxides, tall oil, glassware and car parts.
The deadline
For contracts already concluded, a transition period applies until 25 October 2026. That is a Sunday. In practice, the last working day to complete deliveries is Friday 23 October, which is today. After the deadline, these goods cannot be imported into the EU unless a specific exemption applies.
For the exact HS codes (the customs tariff nomenclature) and the conditions for each item, check the text of the regulation: the descriptions of "car parts" and "glass" are shortened in the summaries.
What else happened in October
- On 12 October 2026 the Council of the EU added 1,569 individuals and entities linked to the Russian military-industrial complex to the sanctions lists. They include 826 Russian companies. It is the largest set of listings ever, and the lists now hold around 4,600 entries in total.
- On 15 October the EU added three more individuals and nine companies that helped bring sanctioned goods into Russia and circumvent the restrictions.
- Listed persons are subject to an asset freeze: no funds or resources may be made available to them, directly or indirectly. If your counterparty or its owner is on the list, you cannot pay them.
- The 21st package also lists 51 companies from the dual-use list, including firms in China, Hong Kong, Türkiye, Kyrgyzstan, India, Kazakhstan and the UAE.
Who is affected
First of all, importers who buy metals, raw materials, glass and parts for the EU market and are not sure of the goods' origin. If you import such goods from China, Kazakhstan or Türkiye, EU customs may ask for proof that the raw materials or components are not of Russian origin. Suppliers and intermediaries in third countries face a separate risk: being listed shuts them out of the EU market and its banks.
What importers should do now
- Review open contracts for ores, zinc, glass and parts: check whether the goods are of Russian origin or routed through an intermediary country.
- Check the HS codes of your goods against Annex XXI of Regulation (EU) No 833/2014, in its current version.
- If a shipment under an old contract is still in transit, ask your customs broker whether it can arrive before 25 October.
- Screen your supplier and its owners against the EU sanctions list (EU Sanctions Map) and the Annex IV list.
- Ask your supplier for documents proving the origin of the goods and raw materials, and keep them in case of an inspection.
- For new contracts, add a sanctions clause and a right to terminate without penalty.
Reference information as of 23 October 2026. The list of goods and codes was checked against a law firm's summary, not the text of the regulation itself. Before signing a contract, check Annex XXI of Regulation (EU) No 833/2014 in its current version, and confirm with a customs broker or lawyer whether your goods fall under the ban and whether an exemption applies.