During a high-profile conference on Ukraine's recovery in London, the European Union approved the long-awaited 11th package of sanctions against Russia. EU ambassadors struggled for weeks to reach a consensus, especially for Greece and Hungary to support the final agreement. 

The 11th package of sanctions, adopted on 21 June 2023, is mainly focused on trade issues. The EU officials have long been concerned about a surge of demand for EU products from Russia’s neighbors like Armenia, Kazakhstan or Kyrgyzstan and from the United Arab Emirates, Turkey or China. The EU has now designed a new mechanism: if third countries, for example in Central Asia, fail to comply with Western sanctions or can’t explain a sudden rise in trade in banned goods, they could face EU punishment. 

For the first time, the European Commission has proposed blacklisting seven Chinese companies accused of supplying banned components to Russia’s military sector, although the list has not yet been officially confirmed. They could be subject to an asset freeze in the EU. However, China’s threat to impose countervailing measures and the reluctance of some EU members to worsen economic ties with Beijing may be an obstacle. Still, there is evidence against these companies of sanctions circumvention, turning a blind eye is not an option, as it undermines the effectiveness and credibility of EU sanctions policy.​

I. Sanctions against Rosatom

Poland and the Baltic countries have suggested including Russia's nuclear energy sector in the 11th EU package of sanctions.

The termination of "operations, contracts and other agreements" with "Rosatom" will occur gradually but take no longer than two years. Instead, Hungary will get a nine-year transition period to complete the construction of the Paks nuclear power plant using Russian technologies. Hungary, France, and Bulgaria are heavily dependent on Russian technologies or, like France, do not want to give up cooperation in this field, repeatedly expressing their disagreement.

Five EU member states operate 15 Russian-made nuclear reactors in Europe for which there is no authorised nuclear fuel alternative to Russian supply – the Czech Republic (six), Slovakia (five), Finland (two), and Bulgaria (two). Germany and Lithuania are for nuclear energy sanctions but show leniency for those like Hungary and France who trade with Russia.

II. Oil and gas sanctions

The EU officials adopted the ban on access to EU ports for ships which engage in ship-to-ship transfers of crude oil or petroleum products at sea if there is cause to suspect the cargo was of Russian origin. Civil society institutions, including us and our partners, have been calling for this for a long time. 

Furthermore, the package includes a stipulation that will prevent Poland and Germany from benefiting from the exception for importing oil from Russia via pipelines, which effectively means imposing sanctions on the northern part of the Druzhba (Friendship) pipeline, one of the world's longest oil pipelines and one of the largest oil pipeline networks in the world.

From the early stage of negotiations on the 11th package, Warsaw was calling to stop Russian oil imports via the northern leg of the Druzhba pipeline going to Germany. Poland also seized imports of Russian diamonds and natural gas, including LNG.

III. Fighting circumvention of sanctions

The 11th sanctions package includes expansion of restricted item lists for controls on transit shipments through Russia to cover additional items, including advanced technology products and aircraft parts. It also provides for introduction of restrictions on the sale, supply, transfer or export of certain items to specific third countries that are at risk of being used for circumvention. It is understood that this would be done through introduction of a “new tool to combat circumvention”, allowing the European Commission to propose restrictions on exports of certain items that are found to be going from the EU to specific third countries and eventually end up in Russia, which proposals need to be approved by the EU Member States.

While there are some steps made in the right direction they are critically insufficiant to stop the war. In particular, the 11th sanctions package fails to ban Russian LNG and does not include measures against Russian diamonds, the nuclear sector of Russia and Belarus, which was, among other things, a demand of Poland.