Sanctions Against Russia: EU Expands Shipping and Energy Restrictions in 21st Package

On 23rd July, 2026, the EU adopted its 21st package of restrictive measures against Russia. The package introduces further measures targeting Russia’s shadow fleet, LNG trades, oil revenues, ports and refineries, while also providing for certain exemptions.

The key shipping related measures for Members’ awareness include:

• Shadow fleet expansion: A further 41 ships have been listed, bringing the total number of EU-designated ships to more than 670. Further entities involved in the shadow fleet ‘ecosystem’ were also sanctioned, including ship managers and a crewing agency. 
• Services to sanctioned ships: The ship-listing criteria have also been widened, such that ships providing services to the shadow fleet, including bunkering, tug services, and ship-to-ship transfers, may themselves be targeted. As part of the latest package, five bunkering tankers were designated.
• Oil price cap: The Russian crude oil price cap has been frozen at USD 44.10 per barrel until 15th July, 2027, subject to an interim review. 
• Ports and refineries: A Georgian refinery (Kulevi Oil Refinery) has been targeted for trading and processing Russian oil, while continuing to export petroleum products to the EU. This listing will enter into force by 25th January, 2027, to provide the refinery time to diversify from its reliance on Russian crude oil, following which the Council will decide whether it is still necessary to list the Georgian refiner.

In addition, as well as refineries in Russia and Belarus, the Russian ports of Olya and Vysotsk were added the transaction ban, in addition to the previously listed ports (i.e. Astrakhan; Makhachkala; Ust-Luga; Primorsk; Novorossiysk; Murmansk; Tuapse; and Karimun Oil Terminal in Indonesia). 

• LNG tanker sales: EU sellers of LNG tankers to third countries are now subject to a notification obligation to the relevant competent authorities. The European Commission is also expected to review, by 25th October, 2026, whether a full ban on LNG tanker sales to any Russian entities / persons, or for use in Russia, should be introduced. 

Should such a ban be introduced, sellers would also be required to take appropriate steps to ensure that LNG tankers sold to third countries are not resold or otherwise transferred to Russian interests, and include written contractual provisions in the sale contract which prohibit a further resale or transfer of the ship to any Russian entities/persons. These provisions are similar to the current oil tanker provisions introduced as part of the EU’s 20th sanctions package, outlined here.

• Russian LNG trades: A temporary, one-year exemption has been introduced for the transfer by ship of Russian LNG to third countries, and related services, including the provision of technical assistance, brokering services, financing or financial assistance. The exemption applies only where the transfer is carried out under a long-term LNG supply contract exceeding one year, concluded before 24th February, 2022, and not amended after that date other than for limited and permitted purposes. The exemption is also subject to review and volume requirements, such that the overall capacity of Russian LNG transferred by Union operators to third countries does not exceed 2025 levels

Other restrictions on Russian LNG remain in place, including, for example, the import ban from 1st January, 2027 in respect of long-term contracts concluded before 17th June, 2025, as introduced as part of the EU’s 19th sanctions package, explained here. 

• The restriction in respect of the prohibition to provide LNG terminal services to any Russian entity was also extended to include non-Russian entities which are more than 50% owned, or controlled directly or indirectly by, a Russian citizen or entity.

• Trade restrictions: Export controls and import bans have been expanded, for example, to include copper ore, nickel ore, lead ore and precious metal ores and concentrates, unwrought zinc, alkaline-earth metals, zinc oxides, chromium oxides, aerospace items and UAV-related goods.

Further information can be found here and here.

If Members have any questions in relation to the above issues, they are invited to contact the Club for further information.