On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force.
The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin crude oil.
The measures also impose restrictions on the provision of technical assistance, brokering services, financing, financial assistance, and insurance / re-insurance.
Under the requirements, importers must provide evidence of the country of origin of the crude oil used for the refining of the petroleum product in a third country, unless the product is imported from a partner country listed in Annex LI (which currently includes Canada, Norway, the UK, the US, Switzerland, Australia, Japan and New Zealand).
The measures also provide that petroleum products imported from third countries that were net exporters of crude oil in the previous calendar year shall be considered as having been obtained from domestic crude oil, rather than from crude oil originating in Russia.
However, competent authorities can rebut this presumption if they have reasonable grounds to believe that the products in question have in fact been obtained from Russian crude oil.
In October 2025, the European Commission published guidance (available here) on how importers can demonstrate compliance with these requirements. Key points from this guidance include the following:
- Operators should have “adequate due diligence procedures” in place to ensure that no Russian-origin crude oil is used in the production of the relevant petroleum products. Operators are “expected” to provide customs authorities with “all relevant information necessary to identify the origin of the crude oil used in the production of the petroleum products, including appropriate evidence on the country where the crude oil used has been extracted”.
- Importers can “reasonably rely upon any documentation providing evidence on the origin of the crude oil from which it has been processed”. However, importers “should exercise caution if they have reasons to believe that such documentation has been falsified or is otherwise erroneous”.
- Operators are advised to insert contractual clauses in relevant contracts with suppliers, including a guarantee / attestation regarding non-Russian crude oil origin. The guidance notes that such a clause should impose liability on the supplier “if it is established that Russia crude oil was used for refining of the imported products”.
- Operators should exercise “enhanced due diligence” in cases where shipments come from Turkey, India or China.
The European Commission guidance also sets out how EU operators should deal with refineries that process any quantity of Russian crude oil, segregated or blended with other crude oils. In such circumstances, operators should exercise “enhanced due diligence”.
The guidance outlines different requirements depending upon whether or not the refinery in question can segregate and process the Russian oil separately.
Furthermore, the guidance provides a list of countries that were net exporters of crude oil in 2024, and therefore able to benefit from the presumption that petroleum products having the non-preferential origin of these jurisdictions have been obtained from domestic crude oil. This table will be updated once a year.
Please do reach out to our team if you have any questions on compliance with these requirements – including as regards the position in practice in relevant EU Member States.
(Baker Mckenzie)
