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EU import ban on Russia wood

10.04.2022

EU import ban on Russia wood

The European Union has agreed on a new sanctions package, including an embargo on Russian wood imports for invading Ukraine.

The legislation can be downloaded in all European languages here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2022:111:TOC

According to article 3i:

It shall be prohibited to purchase, import, or transfer, directly or indirectly, goods which generate significant revenues for Russia thereby enabling its actions destabilising the situation in Ukraine, as listed in Annex XXI into the Union if they originate in Russia or are exported from Russia.

All products belonging to the Combined Nomenclature code 44 are listed, meaning that all wood products are prohibited to be imported from Russia. Wood pulp obtained by a combination of mechanical and chemical pulping processes is also affected by this prohibition.

The prohibitions in paragraphs do not apply to the execution until 10 July 2022 of contracts concluded before 9 April 2022, or ancillary contracts necessary for the execution of such contracts.

Also note that according to article 3k:

It shall be prohibited to sell, supply, transfer or export, directly or indirectly, goods which could contribute in particular to the enhancement of Russian industrial capacities as listed in Annex XXIII, to any natural or legal person, entity or body in Russia or for use in Russia.

Among the goods listed in Annex XXIII – so the goods which cannot be exported to Russia – there are:

4407 19: coniferous wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness of > 6 mm (excl. pine “pinus spp.”, fir “abies spp.” and spruce “picea spp.”);

4407 92 beech “fagus spp.”, sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness of > 6 mm;

4407 94 cherry “prunus spp.”, sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness of > 6 mm;

4407 97 poplar and aspen “populus spp.”, sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness of > 6 mm;

4407 99 wood, sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness of > 6 mm (excl. tropical wood, coniferous wood, oak “quercus spp.”, beech “fagus spp.”, maple “acer spp.”, cherry “prunus spp.”, ash “fraxinus spp.”, birch “betula spp.”, poplar and aspen “populus spp.”);

4408 10 sheets for veneering, incl. those obtained by slicing laminated wood, for coniferous plywood or for other similar laminated coniferous wood and other coniferous wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness of <= 6 mm;

4411 13 medium density fibreboard “mdf” of wood, of a thickness > 5 mm but <= 9 mm;

4411 94 fibreboard of wood or other ligneous materials, whether or not agglomerated with resins or other organic bonding agents, of a density of <= 0,5 g/cm3 (excl. medium density fibreboard “mdf”; particle board, whether or not bonded with one or more sheets of fibreboard; laminated wood with a layer of plywood; cellular wood panels of which both sides are fibreboard; paperboard; identifiable furniture components);

4412 31 plywood consisting solely of sheets of wood <= 6 mm thick, with at least one outer ply of tropical wood (excl. sheets of compressed wood, cellular wood panels, inlaid wood and sheets identifiable as furniture components);

4412 34 plywood consisting solely of sheets of wood <= 6 mm thick, with at least one outer ply of non-coniferous wood (excl. of bamboo, with an outer ply of tropical wood or of alder, ash, beech, birch, cherry, chestnut, elm, eucalyptus, hickory, horse chestnut, lime, maple, oak, plane tree, poplar, aspen, robinia, tulipwood or walnut, and sheets of compressed wood, cellular wood panels, inlaid wood and sheets identifiable as furniture components);

4412 94 laminated wood as blockboard, laminboard or battenboard (excl. of bamboo, plywood consisting solely of sheets of wood <= 6 mm thick, sheets of compressed wood, inlaid wood and sheets identifiable as furniture components)

4416 00 casks, barrels, vats, tubs and other coopers’ products parts thereof, of wood, incl. staves;

4418 40 wooden shuttering for concrete constructional work (excl. plywood boarding);

4418 60 posts and beams, of wood;

4418 79 flooring panels, assembled, of wood other than bamboo (excl. multilayer panels and panels for mosaic floors)

Even in this case, the prohibitions shall not apply to the execution until 10 July 2022 of contracts concluded before 9 April 2022 or ancillary contracts necessary for the execution of such contracts.

Please be also informed that:

  • It shall be prohibited to provide access after 16 April 2022 to ports in the territory of the Union to any vessel registered under the flag of Russia.
  • It shall be prohibited to purchase, import, or transfer, directly or indirectly, coal and other solid fossil fuels, as listed in Annex XXII into the Union if they originate in Russia or are exported from Russia.

The prohibitions in paragraphs 1 and 2 shall not apply to the execution until 10 August 2022 of contracts concluded before 9 April 2022, or ancillary contracts necessary for the execution of such contracts.