EU’s 21st Sanctions Package: New Restrictions Concerning Belarus

On 23 July 2026, the European Union published in its Official Journal a new package of sanctions legislation introducing amendments both to the EU sanctions regimes concerning Russia established by Regulations (EU) No 269/2014 and No 833/2014 and to the specific sanctions regime concerning Belarus established by Regulation (EC) No 765/2006.

The developments of key importance to Belarusian businesses include:

• the designation of two additional entities under the Belarus asset-freeze regime;
• the inclusion of four Belarusian entities in a special export-control list;
• the expansion of the list of goods prohibited from being supplied from the EU to Belarus;
• the introduction of additional restrictions on imports of Belarusian goods into the EU;
• the expansion of restrictions on the participation of Belarusian nationals and residents in the European crypto-asset sector.

Most of the amendments apply from 24 July 2026.

Four Entities Added to the Export-Control List

Four Belarusian entities have been added to Annex V to Regulation (EC) No 765/2006 and are now subject to enhanced export-control restrictions. They are listed in Annex II to Decision 2012/642/CFSP and in Annex V to directly applicable Regulation (EC) No 765/2006.

Inclusion in Annex V does not in itself result in the freezing of all assets of the relevant entity. Annex V is a special export-control list rather than an asset-freeze sanctions list.

As a general rule, the competent authorities of EU Member States will not grant authorisations for the supply to such entities of:

• dual-use goods and technology;
• goods and technology capable of contributing to Belarus’s military and technological enhancement;
• goods capable of contributing to the development of Belarus’s defence and security sector;
• related technical assistance, brokering services, financing and financial assistance.

Authorisations may be granted only in the limited circumstances expressly provided for by the Regulation.

Expansion of Restrictions on Supplies to Belarus

Regulation (EU) 2026/1846 expands the list of goods and technology that may not be sold, supplied, transferred or exported to Belarus.

The newly restricted items include certain categories of:

• nickel powders, nickel and nickel alloys used in corrosion-resistant coatings for aircraft engines;
• beryllium powders;
• self-adhesive films, tapes and strips used in the aviation and defence industries;
• equipment and components for unmanned aerial vehicles;
• ground-support equipment for UAVs;
• jamming and interception systems;
• launch systems and servomotors;
• flight-termination systems for UAVs and missiles;
• certain radio-frequency systems and software.

The restrictions apply not only to the physical supply of goods, but also to the transfer of technology, the provision of technical assistance and brokering services, and the provision of financing or financial assistance.

New Restrictions on Imports of Belarusian Goods into the EU

The list of goods that may not be purchased, imported or transferred, directly or indirectly, into the EU has been substantially expanded where such goods:

• originate in Belarus; or
• are exported from Belarus, irrespective of their origin.

The new restrictions apply, in particular, to:

• copper, nickel and lead ores and concentrates;
• precious-metal ores and concentrates;
• zinc oxide and zinc peroxide;
• chromium oxides and hydroxides;
• certain alkaline-earth metals and inorganic chemical products;
• tall oil;
• unwrought zinc;
• certain types of glass and glassware;
• vehicle bodies and cabs;
• motor-vehicle parts and accessories.

Related technical assistance, brokering services, financing and financial assistance are also prohibited.

A wind-down period is available for certain newly restricted product categories. Contracts concluded before 24 July 2026 may continue to be performed until 25 October 2026 in respect of certain types of glass and glassware, tall oil, vehicle bodies and cabs, and motor-vehicle parts and accessories.

The wind-down period applies only to the expressly specified customs codes. The mere fact that a contract was concluded before the restrictions entered into force does not in itself guarantee that the contract may continue to be performed.

Derogations for Civilian Internet Infrastructure

At the same time, the EU has clarified certain derogations intended to support the operation of civilian internet infrastructure in Belarus.

The competent authorities of EU Member States may authorise the supply of certain telecommunications devices, data-storage media and computing equipment where it is established that they are:

• intended for non-military use;
• intended for a non-military end user;
• necessary for civilian electronic communications networks.

The relevant network must not, however, be owned by an entity that is publicly controlled or more than 50% publicly owned.

Accordingly, this is not a general exemption for the Belarusian telecommunications sector, but a limited authorisation mechanism intended for independent civilian infrastructure.

New Restrictions on Belarusian Participants in the European Crypto-Asset Sector

From 25 August 2026, the prohibition on the participation of Belarusian nationals and natural persons residing in Belarus in EU companies providing crypto-asset services will be expanded.

Such persons will be prohibited, directly or indirectly, from:

• owning the relevant company;
• controlling it;
• holding positions on its governing bodies.

Previously, the restriction was primarily framed by reference to companies providing crypto-asset wallet, account and custody services. It will now apply to all crypto-asset services within the meaning of the EU Markets in Crypto-Assets Regulation, or MiCA.

The restriction applies to entities incorporated under the laws of an EU Member State. It does not amount to a general prohibition on the activities of Belarusian crypto businesses, but it substantially limits the ability of Belarusian nationals and residents to own, control or manage licensed EU crypto-asset service providers.

Additional Protection for EU Companies Against Sanctions-Related Claims

The EU has also expanded the mechanism allowing EU persons to recover losses arising from proceedings brought against them in third countries.

Subject to certain conditions, EU companies will be able to seek compensation before the courts of EU Member States for direct and indirect losses, including legal costs, where claims are brought against them outside the EU in connection with the non-performance of contracts as a result of EU sanctions.

This provision may be relevant to Belarusian companies considering bringing claims against EU counterparties before Belarusian or other non-EU courts following a refusal to perform contractual obligations on sanctions grounds.

Even where a judgment is rendered outside the EU, the EU defendant may, subject to the conditions set out in the Regulation, bring a separate action in the EU to recover the resulting losses.

Impact of Amendments to the EU Sanctions Regime Concerning Russia

At the same time, the EU amended Regulations (EU) No 269/2014 and No 833/2014 governing sanctions concerning Russia.

Belarusian persons do not automatically fall within the scope of the EU sanctions concerning Russia merely because they are incorporated or located in Belarus.

However, the EU sanctions concerning Russia may apply to a transaction involving a Belarusian company where, in particular, the transaction involves:

• a Russian end user;
• the supply of goods for use in Russia;
• a Russian sanctioned person;
• an intermediary or transit arrangement intended to circumvent applicable restrictions;
• the participation of a Belarusian company in the supply of goods or services prohibited for use or provision in Russia;
• links to entities included in the newly expanded Russian sanctions or export-control lists.