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Key Takeaways:
- EU introduces additional export and import restrictions targeting Russia and Belarus with its 20th sanctions package
- General Court confirms export price as a reasonable basis for customs valuation under the UCC in Case T-296/25
- EU Council and Parliament reach political agreement on new steel measure to address global overcapacity and replace existing safeguards
- Trade defense actions on China: Provisional anti-dumping duties imposed polyamide yarn
EU’s 20th sanctions package against Russia
On 23 April 2026, the Council adopted its new set of EU restrictive measures against Russia and Belarus.
For the first time, the Anti-circumvention is being activated. As of 23 April 2026, the sale, supply, transfer, or export of computer numerical controlled machines and certain telecommunication equipment to Kyrgyzstan is prohibited.
The EU adds 60 new entities to annex IV to Decision 2014/512/CFSP, the list of persons, entities and bodies supporting Russia’s military and industrial complex. Tighter export restrictions are imposed regarding dual-use goods and technology.
The EU also adds 115 new entries to the list of Russian and third country (e.g., China, the UAE, Uzbekistan,...) entities and individuals subject to an asset freeze and to whom no economic resources shall be made available.
The new package increases the list of items identified as being used in Russia’s war effort and which export to Russia is prohibited, most notably laboratory glassware, high-performance lubricants and additives. Other export restrictions are included, in particular for chemicals, rubber, small hardware such as screws or bolts, tractors, etc.
Additionally, the EU introduces new import restrictions on goods generating significant revenues for Russia. The covered goods are, among others, certain raw materials, metals and minerals, scrap of steel and other metals (e.g., platinum, copper, nickel & aluminum waste and powders, cobalt,...), chemicals including silicon & a quota on ammonia, articles of vulcanized rubber, salt, gravel, tanned fur skins, worth over EUR 530 million.
Furthermore, the package sharpens the measures on energy and maritime logistics by introducing a ban on providing LNG terminal services to Russian entities or entities owned by Russian individuals or entities, starting 1 January 2027. As a reminder, the 19th package introduced an import, purchase and transfer ban on LNG originating in or exported from Russia, as well as all related services. The 20th package also prohibits the purchase, import or transfer of natural gas condensate from LNG production plants, and the provision of services related to its trading, brokering or transport to third countries.
It also increases the shadow fleet listing by adding 46 additional vessels amounting to a total of 632 vessels. Finally, it lists two new Russian ports: Murmansk and Tuapse as well as the Indonesian port of Karimun for their connections in providing services to the shadow fleet thus facilitating circumvention.
In parallel, the amendments regarding Belarus mirror several trade restrictions, expanding the lists of restricted goods, extending transit restrictions to reduce circumvention risks, and introducing additional services restrictions such as services related to tourism and managed security.
General Court in case T296/25: Export price as a “reasonable means” for customs valuation
In its judgment in Lidikar OOD (T‑296/25, 25 March 2026), the General Court confirmed that information on the export price declared in a third country, transmitted to EU customs authorities under an international customs cooperation agreement, may qualify as “data available in the customs territory of the Union” within the meaning of Article 74(3) of the Union Customs Code (UCC).
The Court held that this concept must be interpreted broadly and cannot be limited to data generated or collected within the EU. What matters is that the data are factually available to EU customs authorities and can be used for customs valuation purposes, especially where they are obtained through formal cooperation mechanisms such as the Canada–EU Customs Cooperation Agreement and CETA.
The General Court further clarified that the use of the declared export price as a basis for determining the customs value under the “fall‑back” method does not, as such, conflict with EU customs law nor with the WTO Customs Valuation framework, provided that the use of such data complies with the limits inherent to the residual valuation method.
Provided that the customs value is not determined on the basis of arbitrary or fictitious values and that the export price reflects the economic reality of the goods concerned, a price communicated by a third‑country customs authority may constitute a legitimate and reasonable reference point for customs valuation in the EU.
Political Agreement on new EU Steel Measure
The Council and European Parliament have successfully concluded the trilogue negotiations about a new EU Steel Measure. This will result in a regulation “aiming at addressing the negative trade-related effects of global overcapacity on the EU steel market” and will replace the EU steel safeguard measures which are in force since 2018 and are set to expire on 30 June 2026.
The new measure will continue working with tariff-rate quotas and will apply to 30 categories of steel products. Compared to the current steel safeguard measures, the quotas are significantly lower and the applicable duty rate once a quota is exceeded will be 50% instead of 25%. The quotas are set for each quarter but will be revised annually. Carry-over from one quarter to another is foreseen for the first year but will be subject to Commission approval for the subsequent years.
The new instrument applies the “melt and pour” principle. Quotas will be allocated taking into consideration the country where imported steel is melted and poured (where the relevant raw steel or iron was initially produced in liquid form and subsequently cast into its first solid state). It must still be decided what type of evidence will be required from importers to substantiate the country of melt and pour.
It is also foreseen that a declaration will be added to the Regulation in which the European Parliament and the Council reaffirm the intention to gradually phase-out the import of Russian steel products.
Companies importing covered steel products will have to continue managing quota volumes; must engage timely with suppliers to collect necessary documentation and must prepare themselves to be confronted with higher tariffs. Using special customs procedures could offer an opportunity to mitigate the impact.
The new instrument should apply as from 1 July 2026 but is still pending formal approval by the European Parliament and Council.
Provisional anti-dumping duty on import of yarns of polyamide originating in China
The European Commission has taken further steps to address unfair trade practices and protect the EU industry, with new provisional anti-dumping duties imposed on imports of yarns of polyamide (T.H. 5402) originating in China, applicable as of 28 March 2026. The duty rates range from 57,7% to 90,1%.