The Government have announced new measures to prohibit the export, supply and delivery, and making available to, or for use in Russia, of newly sanctioned items as well as the provision of related ancillary services. This includes chemicals, electronics, machinery, plastics, and metals added to existing schedules in the 2019 Regulations, namely:
- Schedule 2A (critical-industry goods and critical-industry technology)
- Schedule 3 (energy-related goods and energy-related technology)
- Schedule 3C (defence and security goods and defence and security technology)
- Schedule 3E (G7 dependency goods and G7 dependency technology)
- Schedule 3I (Russia’s vulnerable goods and Russia’s vulnerable technology)
Additionally, there are new prohibitions on the transfer, making available and ancillary services related to certain technology and software. This includes energy related, advanced and industrial manufacturing technology, and business enterprise, industrial design, and oil and gas related software and technology. They are detailed by amendments and additions to the 2019 Regulations in:
- Chapter 4 (energy-related goods, energy-related technology and related activities)
- Chapter 4H (G7 dependency and further goods and G7 dependency and further technology)
- Chapter 4M (Russia’s vulnerable goods and Russia’s vulnerable technology)
- Chapter 4N (sectoral software and technology)
Exceptions
There are some exceptions to the prohibitions, which are set out in detail in the 2019 Regulations, and licences can be granted in very limited circumstances.
The legislation for the new measures is the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, found here:
The legislation amends sanctions legislation originally introduced in 2014. The latest version of the legislation is the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”), found here:
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Further guidance and support
Guidance on the scope of sanctions against Russia, including the circumstances in which licences can be granted, will shortly be updated and can be found on the Russia sanctions: guidance page.
Guidance on the technology transfer and software sanctions can be found here: Complying with technology transfer sanctions and Complying with sectoral software sanctions.
For further information on licensing, compliance and enforcement for trade sanctions relating to standalone services, contact the Office of Trade Sanctions Implementation (OTSI).
For further information on export controls and trade sanctions relating to the export of goods and provision of ancillary services, contact the Export Controls Joint Unit (ECJU).
For further information on import related sanctions, contact DBT’s Import Licensing Branch.
The Export Support Service is ready to help with any other enquiries about exporting or trading with Russia or Ukraine that are not specific to the requirement for export licences.
Contact ECJU
General queries about strategic export licensing
Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
Email [email protected]
Telephone 020 7215 4594