Recital 7

(7) In order to strengthen the effectiveness of the restrictive measures imposed in response to Russia’s war of aggression against Ukraine, it is necessary to address the risk of circumvention of those measures through indirect exports via third countries. Goods and technology listed in Annex VII to Regulation (EU) No 833/2014 might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector, including when exported under the guise of being intended for civilian end-use. The prohibition on indirect exports covers the export of items that are listed in the Annexes to Regulation (EU) No 833/2014, including via a third country. Competent authorities should take timely preventive action where there is a credible risk that such items exported to third countries might ultimately be diverted to Russia. Therefore, Decision (CFSP) 2025/1495 provides Member States with an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in Annex VII to Regulation (EU) No 833/2014 to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in Russia or that the end-use of the items may be for Russian entities. That measure is not intended to impose a new blanket restriction but to equip Member States with an effective and proportionate tool to investigate and prevent possible circumvention of restrictive measures, while ensuring a harmonised interpretation and legal clarity for exporters. The scope of the indirect export prohibition clause should not be affected by that measure. It is at the discretion of Member States to decide whether that measure or the indirect export prohibition clause is to be applied as a mechanism of enforcement in cases in which the end destination of the items may be in Russia or the end-use of the items may be for Russian entities.

← Recital 6 · All articles · Recital 8 →

Source: EUR-Lex (Cellar) · retrieved 2026-10-16 · Text as adopted (Official Journal); later amendments are not incorporated in this text.