After the 16th package of sanctions against Russia was adopted by the EU it was noted in the Circular that the package included Article 5ae of Council Regulation 833/2014 introducing a ban to engage in any transaction with ports listed in Part A of Annex XLVII, namely: Ust-Luga, Primorsk, Novorossiysk, Astrakhan and Makhachkala. Paragraph 3 of the Article 5ae provided an exhaustive list of exemptions from this ban.
It was also noted that the International Group was seeking clarification on whether the transport of certain cargoes, that can still be exported from Russia, e.g. coal, is still permitted as there was no specific exemption for such cargoes.
On 20 March 2025 the EU published FAQs on infrastructure transaction ban introduced in Article 5ae.
Several Clubs have published a summary of these “FAQs” which could perhaps be better termed “clarifications”.
E.G., https://www.steamshipmutual.com/sites/default/files/medialibrary/files/L.460_0.pdf
https://www.swedishclub.com/news/circulars/the-oil-price-cap-and-eu-16th-sanctions-package-continued-requirement-for-voyage-attestations/
https://www.ukpandi.com/news-and-resources/circulars/article/circular-08/25-16th-package-faqs-coal-exception/
https://www.westpandi.com/news-and-resources/notice-to-members/2025-2026/no-2-2025-26-update-to-ntm-no-1-25-26-regarding-th/
The EC publication is at:
https://finance.ec.europa.eu/document/download/85a81676-9f77-4d35-9c48-003e5535763b_en?filename=faqs-sanctions-russia-infrastructure-transaction-ban_en.pdf