By Regulation (EU) 2026/506 of 23 April 2026, the European Union has once again significantly expanded the Russia sanctions under Regulation (EU) No 833/2014. Of particular relevance for companies are the newly introduced import and export prohibitions, together with the accompanying transitional provisions for contracts already in existence.
The new prohibitions do not take effect immediately in every case. For certain groups of goods, the Regulation provides time-limited transitional arrangements in order to allow the performance of contracts already concluded beforehand. Companies should, however, carefully check whether the conditions of the relevant legacy contract clause are actually met.
Which contracts may still be performed
The Regulation contains different transitional periods for individual groups of goods.
Import restrictions under Article 3i
For numerous groups of goods referred to in Article 3i, a transitional period applies until 25 July 2026. The prohibitions do not apply, to that extent, to the performance of contracts concluded before 24 April 2026, or to the performance of ancillary contracts required for the execution of such contracts.
Affected, among others, are certain:
- salts,
- ores,
- rubber products,
- chemicals,
- metals and metal scrap (for example, aluminium, copper, or nickel scrap).
Longer transitional periods apply to individual goods. For instance, certain products under CN code 7403 19 (refined copper) may still be imported under permissible grandfathering contracts until as late as 25 January 2027.
Export restrictions under Article 3k
A comparable contract arrangement is contained in Article 3k(3al) of Regulation (EU) No 833/2014 for goods under the CN codes listed in Annex XXIIIH. This covers, in particular, industrial goods relating primarily to metalworking and mechanical engineering, as well as selected intermediate products and components, such as goods under CN codes 2931, ex 2932, 3603, 4001, 4007, ex 4015, ex 4016, 4017, 6805, ex 7318, 7325, 8209, 8311, and 8701 95 90.
For these goods, the following transitional arrangement applies: contracts concluded before 24 April 2026 may, in principle, still be performed until 25 July 2026.
When does a protected legacy contract exist?
The decisive question is whether a legally binding contract with a sufficiently specific scope of performance already existed before the relevant cut-off date. In particular, the following elements should already have been fixed, or at least been clearly determinable, at that time:
- the contracting parties,
- the goods concerned, including their specification,
- quantity and price,
- the timing or modalities of delivery or performance.
Mere statements of intent or bare framework agreements without a concrete acceptance obligation are, as a rule, not sufficient.
Risks of subsequent contract amendments
Particular caution is warranted where existing contracts are amended. If material elements of the contract are changed after the cut-off date, the protection of the legacy contract arrangement can be lost.
Amendments to the following are particularly critical:
- the contracting parties,
- the subject matter of the delivery,
- the quantity,
- the price,
- the delivery deadlines or delivery modalities.
As a rule, only adjustments that serve exclusively the technical or organisational execution of the original contract are unproblematic. Where an amendment, by contrast, results in an economically new arrangement, there is a risk that the authorities will classify the transaction as a new contract, with the effect that the transitional arrangement no longer applies.
Recommended actions for companies
Companies should promptly review ongoing Russia-related and third-country business connected with the new sanctions rules.
The following are particularly important:
- complete documentation of the conclusion of the contract before 24 April 2026,
- traceable documentation of the original scope of performance,
- a record of all subsequent contract amendments,
- robust internal approval and compliance processes.
In the area of export control in particular, a documented case-by-case review is advisable, so as to be able to demonstrate to the authorities why a transaction was classified as a permissible legacy contract.
Conclusion
The legacy contract arrangements under the 20th sanctions package against Russia do not create blanket protection for existing business. Only contracts that were already bindingly concluded before 24 April 2026, and that are not subsequently materially amended, are protected.
Companies should therefore review their existing Russia-related business at an early stage, from both a legal and an export control perspective, in order to avoid sanctions violations and liability risks.
Do you need assistance with the legally sound assessment of your existing contracts? Please feel free to get in touch!
