It is important to impose restrictions that take into account that Russia has been circumventing EU sanctions through third countries such as Belarus. As for now, EU exporters are allowed to legally sell goods to Belarus or to other third countries with Belarus as the official transit point. These goods can then be transferred to Russia. This includes goods and technology that could contribute to Russia’s armed aggression against Ukraine. For trade purposes, Belarus and Russia should be treated as part of a single Union State.
Otherwise, Belarus will continue to serve as a gateway for banned goods. The EU Parliament has recognised this in its 29 February Resolution calling “the sanctions against Belarus to be fully aligned with those against Russia” (para. 32).
In response to Russia’s aggression against Ukraine, the EU has introduced a wide-ranging package of sanctions and export controls both against Russia and Belarus. However, some significant disparities have been found between these sanctions regimes. They include, but are not limited to, materials that could contribute to Russia’s industrial capacities, semiconductors manufacturing equipment, different types of software and oil refining and liquefication of natural gas.
These disparities are not adequately addressed yet and as a result, there are not enough measures to prohibit re-export of EU goods to Russia through Belarus.
According to Eurostat, between January and May 2023 Belarus imported goods from the EU worth €3.3 billion. This is 8% of Belarus’ imports. There is also clear evidence that transshipment of goods through Belarus has been growing rapidly these years. According to statistics, 6 million tonnes of goods were transhipped from Belarus via Russian ports in the first six months of 2023, compared to 1.5 million tonnes in the first half of 2022. Mostly these were materials and goods sanctioned by the EU. There were also numerous schemes to circumvent sanctions by transporting goods (including luxury ones) from EU to Russia through Belarus as a gateway point.
Trap Aggressor takes part in a public appeal to EU to address the disparity in export bans on:
• goods which could contribute to the enhancement of Russia’s industrial capacities;
• luxury goods;
• semiconductors manufacturing equipment;
• oil refining and liquefaction of natural gas;
• tankers for the transport of crude oil or petroleum products; and
• software for the management of enterprises and software for industrial design and manufacture.
The EU should also prohibit the transit of sanctioned goods through Belarus.