Recital 32

(32) The Commission will assess the impact that the entry into force of the existing obligation under Article 12g of Regulation (EU) No 833/2014 to use a ‘no-Russia clause’ has on deterring circumvention. It will also assess very closely trade data, export statistics and other information concerning circumvention patterns regarding the goods referred to in that Article, including the role that subsidiaries of Union operators in third countries may play in such patterns. On that basis, the Commission will assess whether the ‘no-Russia clause’ is appropriate for its purpose and consider any other appropriate actions to curb Russia’s access to sensitive goods which enable it to pursue the war in Ukraine, including the possibility of requiring Union operators to ensure that their subsidiaries in third countries also use the ‘no-Russia clause’.

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Source: EUR-Lex (Cellar) · retrieved 2026-10-17 · Text as adopted (Official Journal); later amendments are not incorporated in this text.