Supplier outside the EU
You are a supplier outside the EU and your customer asks for a No Russia clause
Regulation 833/2014 binds EU operators. It reaches you through the contract: your European buyer is required to prohibit re-export to Russia and, for sensitive goods, to check where the goods go next. That is why the conversation starts with the CN code of your product.
中文摘要 · summary in Chinese
您不是欧盟企业，欧盟第833/2014号条例并不直接约束您，但您的欧盟客户受其约束，并会通过合同把义务转给您。
重点是两条：合同中的“禁止转口俄罗斯”条款（第12g条，自2024年3月20日起适用于附件XI、XX、XXXV和XL所列货物），以及对高优先级货物的尽职调查（第12gb条），客户会因此询问最终用户、目的地和运输路线。
第一步永远是您产品的八位CN编码：在本站免费查询，即可看到制裁状态、所依据的附件与条款、禁令方向以及法规版本日期，并附EUR-Lex原文链接。
如果客户要求书面证明，可购买带日期的核查报告（29欧元），双方合同档案均可使用。
免费查询 CN 编码 →What is required of you
- The No Russia clause in the contract (Art. 12g). It applies from 20 March 2024 to sales to a third country of goods from Annexes XI, XX, XXXV and XL, and firearms from Regulation 258/2012. It does not apply to sales to partner countries: the United States, Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein and Iceland.
- Questions about the end customer for common high priority items (Art. 12gb). Your customer must document a risk assessment of diversion to Russia, so they will ask for the recipient, the destination country and the route.
- What a breach costs you: losing the customer, goods stopped at the EU border, and for repeated circumvention a listing in Annex IV, which cuts off access to dual-use goods.
What to keep in the file
- The eight-digit CN code of the goods, the same one that goes on the invoice and the customs declaration.
- A dated printout of the sanctions status check, with the version of the regulation. "We checked last year" is not evidence.
- A signed No Russia clause and an end-user statement.
Frequently asked questions
Do EU sanctions apply to a company outside the Union?
Not directly, apart from exceptions concerning subsidiaries of EU operators. In practice yes, because your European counterparty must impose the re-export ban on you and document that it knows where the goods go. Without that, it is exposed to criminal liability itself.
How do I check whether my product is covered?
Enter the CN code in the search. You will see the regime, the annex, the article, the direction of the ban and the version date of the act, with a link to EUR-Lex. The check is free and requires no account.
The customer asks for proof of the check. What do I send?
A dated report with the code, the status, the legal basis, any exemption and the version of the regulation. That document costs EUR 29 and works for the contract file on both sides.