EU sanctions do not close trade with Russia across the board. They prohibit defined categories of goods, each tied to a customs code and a specific article of Council Regulation (EU) No 833/2014 — in force since 31 July 2014 and rewritten with every package since February 2022, twenty-one of them by August 2026. The latest is the 21st package, adopted by the Council on 23 July 2026: its sectoral measures were enacted by Council Regulation (EU) 2026/1848 of 23 July 2026 amending Regulation (EU) No 833/2014, published in the Official Journal on 23 July 2026 and in force from 24 July 2026. The preceding 20th package was adopted on 23 April 2026. Every new package reshuffles the annexes: entries are added, codes refined, thresholds revised. A parallel regime, Council Regulation (EC) No 765/2006, carries most of the same restrictions across to Belarus.
How the list is built
The list combines two distinct prohibitions inside the Regulation. Article 3h bans luxury goods listed in Annex XVIII. Article 3k bans industrial and dual-capacity goods listed in Annex XXIII — the economically critical items that feed Russia's industrial base. One prohibition targets prestige consumption, the other raw materials, chemicals, metals and machinery; both catch related technical assistance and financing alongside the goods themselves.
Classification runs on the Combined Nomenclature, so the control point is the CN code in the export declaration, not the commercial name of the product. The luxury ban first appeared in the fourth package in March 2022, and the annexes and thresholds have been revised several times since; in parallel the EU is closing circumvention routes through third countries. In practice three checks matter: the exact CN classification, the end-use of the item, and a "No Russia" clause in contracts with third-country counterparties — recent packages deliberately target re-export through intermediaries, so the absence of a Russian consignee is no longer enough.
Risk categories
The luxury block (Annex XVIII) applies once value passes EUR 300 per item, measured on the statistical value declared at export; some entries are banned at any price. Inside: alcohol, perfumes and cosmetics, leather and furs, caviar and truffles, works of art and antiques, jewellery, pearls and precious metals, watches, sports equipment, musical instruments over EUR 1,500. Vehicles and equipment carry their own thresholds: EUR 50,000 for cars and other passenger transport, EUR 5,000 for motorcycles, EUR 750 for household electronics, EUR 1,000 for audio and video equipment.
The industrial block (Annex XXIII) runs far wider and mostly without thresholds: inorganic and organic chemicals, mineral products and fuels, plastics and rubber, wood and paper, textiles, stone and glass, metals and articles thereof, machinery and electrical equipment, transport from railway stock to aircraft. The logic is simple: anything able to feed the industrial and military-industrial base is taken out of circulation — down to pen nibs.
Private transactions and bank screening
In family-office practice the list surfaces wherever assets move: buying and selling art and collectibles, high-value watches, cars and wine, shipping personal effects, gifting. The prohibition applies to private transactions as much as to commercial ones — selling a painting or a car to a Russian-resident buyer, or sending such an item to Russia, falls under the sanctions however "personal" the deal. Narrow exemptions exist — travellers' personal effects, diplomatic needs — but they are read strictly.
Any such operation is screened by a bank or payment provider for sanctions risk — as part of source of funds control and correspondent-banking compliance; at the slightest doubt the payment is stalled or rejected. The topic is covered more broadly in the notes on AML/KYC for private clients and on the status of unfriendly countries. If the goods ban is only one of the questions in play, the overall frame — where to start and in what order to work through the rest — is set by the map of the sanctions cluster.
Q/A
Does a product’s commercial name determine whether an EU export ban applies?
No. The decisive starting point is the current Combined Nomenclature code and whether it appears in the relevant annex to Regulation 833/2014. Then check the exact description, value or technical threshold, destination, end use, parties and any narrowly worded exception or authorisation.
Is every luxury item worth no more than €300 automatically permitted?
No. For Annex XVIII, Article 3h uses a default threshold above €300 per item unless the annex specifies another one. Goods below that figure may still fall under another annex or prohibition, so the current CN code, annex, value rule, destination and use must all be checked.
Does a private sale or gift fall outside the luxury-goods ban?
No. Article 3h covers sale, supply, transfer and export, directly or indirectly; the non-commercial character of a transaction is not by itself an exception. The item, value threshold, destination or use in Russia and the Regulation’s personal and territorial scope still have to be tested.
Can I avoid the ban by routing goods through a third country?
No. A third-country route does not cure a direct or indirect supply to Russia or intentional circumvention. Article 12g’s contractual “no re-export to Russia” clause applies to specified sensitive goods, not every product, and it does not replace the underlying sanctions analysis and due diligence.
May a traveller take personal jewellery from the EU to Russia?
Article 3h contains a narrow exception for goods under CN 7113 00 00 and 7114 00 00 that are owned for the personal use of the traveller, or immediate family travelling with them, and are not intended for sale. It should not be treated as a blanket personal-effects exception for every listed luxury good.