EU Commission removes Russia as a destination country from the scope of application of the EU GEAs

In response to Russia's sustained attack on Ukraine, which is contrary to international law, the EU Commission has taken the further measure of cancelling the Union's previously existing general export authorisations for Russia by way of its Delegated Regulation (EU) 2022/699 of 3 May 2022.

General export authorisations (GEAs) are export authorisations that allow the export of several or a large number of items to an unlimited number of recipients. The prerequisite for this is that the export complies with the conditions in the respective general authorisation. Accordingly, general authorisations significantly reduce the efforts that are required to export or transfer certain dual-use items.

Both the European Union and the Federal Republic of Germany have issued general authorisations. The recast of the Dual-Use Regulation (Regulation (EU) 2021/821) introduced eight EU general export authorisations for the export of certain items to selected destinations, subject to ancillary provisions and conditions. Of these, three EU general export authorisations could previously be used for exports to Russia:

• EU003 (re-export of goods after their repair or replacement in the EU)
• EU004 (export of goods for trade fairs or exhibitions)
• EU005 (export of telecommunications equipment)

With the entry into force of Delegated Regulation (EU) 2022/699 on 5 May 2022, these general export authorisations can no longer be used for exports to Russia. However, the practical impact of this amendment should be relatively limited, as the export of dual-use items listed in Annex I of the EU Dual-Use Regulation is fundamentally prohibited under Article 2 (1) of Regulation 833/2014 (as adapted by Regulation (EU) 2022/328), regardless of the recipient or end-user. In this respect, the primary purpose of the current adaptation is to standardise the regulations and to help avoid misunderstandings about the applicability of the general authorisations.

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