EU Russia sanctions update: Steel restrictions take effect, Fridman and Usmanov delisted by the EU, and proposals for additional restrictions

Recent developments highlight the continuing complexity of Russia-related sanctions compliance across the EU, UK, and US. Developments of particular note for businesses include:

• The expiry of certain transition periods relating to Russian iron and steel products;
• The EU’s decision to remove Mikhail Fridman and Alisher Usmanov from its asset freeze list while several Member States consider national measures; and
• The EU’s continued expansion of Russia-related sanctions through its latest sanctions packages.

Restrictions on Russian iron and steel: Key transition periods have expired

A number of transitional arrangements applying to imports of iron and steel products under the EU’s Russia sanctions regime have now expired or are approaching expiry, with certain transitional quota arrangements also due to be reduced further from 1 October 2026.

Specifically:

• The transitional arrangements for pig iron (CN code 7201) and direct reduction of iron ore (CN code 7203) expired on 31 December 2025, and imports of those products have been prohibited as of 1 January 2026 (Article 3i).
• The current transitional quota arrangements under Article 3g for semi-finished products of iron or non-alloy steel (CN code 7207 12 10) and semi-finished products of other alloy steel (CN code 7224 90) expire on 30 September 2026. Reduced quota volumes will then apply until 30 September 2027, with the final quota period expiring on 30 September 2028, after which the restrictions will apply in full.

The restrictions under Article 3g are not limited to direct imports from Russia, but also prohibit the import or purchase of certain iron and steel products processed in third countries where those products incorporate Russian-origin iron or steel inputs specified in Annex XVII. As a result, companies sourcing steel products from jurisdictions outside Russia cannot rely solely on the country of export or customs origin and should assess whether Russian-origin inputs were used at any stage of the manufacturing process.

Businesses that previously relied on transitional arrangements for Russian products should review their supply chains carefully to ensure that imports remain permissible following the expiry of the relevant derogations and quota mechanisms.

Regulatory scrutiny has increasingly focused on the provenance of underlying steel inputs rather than solely on the country of export. Businesses should therefore revisit supplier due diligence questionnaires, contractual information rights, and document-retention processes to ensure that they can substantiate compliance with the relevant restrictions if requested by customs or sanctions authorities.

EU delists Mikhail Fridman and Alisher Usmanov

On 22 September 2026, EU Member States agreed to remove Mikhail Fridman and Alisher Usmanov from the EU’s Russia sanctions list. Both individuals had been subject to EU asset freeze and travel ban measures since February 2022, following Russia’s invasion of Ukraine. The decision means that EU asset freeze and travel ban measures no longer apply to those individuals under the EU sanctions regime.

The delisting has proved controversial with several Member States, with the Baltic and Nordic regions in particular opposing the delisting during negotiations. Moreover, certain Member States have moved to maintain restrictions at national level. Latvia announced that it would pursue national sanctions against Mikhail Fridman and Alisher Usmanov, and Estonia also imposed national sanctions on both individuals immediately following the EU delisting and publicly called on other jurisdictions to take similar action. Lithuania has similarly announced steps towards the adoption of national restrictive measures. As a result, the practical impact of the EU delisting may vary across Member States, notwithstanding their removal from the EU sanctions list.

Importantly, the EU delisting does not affect the position under UK or US sanctions. Businesses should therefore not assume that the EU delisting automatically removes all restrictions across the European Economic Area. Counterparty screening and transaction assessments should continue to consider applicable national sanctions measures, in addition to EU, UK, and US restrictions.

Proposed 22nd EU Russia sanctions package

The EU is already preparing a further round of Russia-related sanctions following the adoption of the 21st package in July 2026. While the package has not yet been formally adopted, EU policymakers have indicated that additional measures are expected to focus on Russia’s military-industrial complex and further expansion of individual and entity listings.

EU officials have also signaled continued interest in expanding measures targeting sanctions circumvention, Russia’s shadow fleet, financial actors, crypto exchanges, and supporting networks operating outside Russia. Although the final scope of the package remains under negotiation, there appears to be broad political support for increasing pressure on Russia.