Lithuanian Customs, in implementing EU sanctions, will pay increased attention to export and transit control of goods shipped to third countries via Belarus and Russia.
As noted by Lithuanian Customs, attempts to transport goods along “odd routes” are becoming increasingly frequent. For example:
- Goods from an EU country (Slovakia or the Czech Republic), which neighbors Turkey, are being imported into Turkey via Lithuania’s border with Belarus or Russia.
- It is declared that goods from Germany or Estonia are being transported to the United Kingdom or other third countries (South Korea, Thailand, the United Arab Emirates)—which are not subject to EU sanctions—via the M-10 (Medininkai) road checkpoint on the Belarusian border.
- A passenger car from Germany declared for export to Kazakhstan is being attempted to be shipped through the Kibartai road customs post on the border with Kaliningrad Oblast.
“Lithuanian Customs has well-founded suspicions that the true destination of such goods is Russia, and that choosing such routes is an attempt to circumvent sanctions. In accordance with the European Commission’s recommendation (‘having regard to Article 12 of Council Regulation No 833/2014’), national competent authorities must not allow release of goods if they have reasonable grounds to suspect sanctioned‐goods circumvention. Lithuanian Customs, having deemed a route via Belarus or Russia illogical and economically unjustifiable, will block export on that route and recommend an alternative EU departure point and Customs office,” the statement says.
Representatives from Finland, Estonia, Latvia, Lithuania, Poland and Norway (an EFTA member) met to discuss measures to combat EU sanctions circumvention (details here).
Because of atypical increases in trade with certain third countries—and to prevent possible sanctions evasion—Lithuanian Customs is tightening controls on sanctioned goods. New rules apply from June 5, 2023 to exports via or in transit through Russia and/or Belarus.
“We recommend that businesses thoroughly verify sanctions-listed goods before export, logistics services or Customs declaration, and ensure that goods transit Russia and/or Belarus only en route to a third country, are not intended for use or sale in Russia or Belarus, and are not supplied to any person or entity there,” Lithuanian Customs advises.
To enforce these rules, Customs will require additional evidence that:
- The goods will not be sold, and ownership will not change after they leave the EU.
- Transit via Russia and/or Belarus is only part of a journey beginning and ending outside those countries.
- No resale, processing, storage or reloading (including trailer swaps) occurs in transit, nor are sanctioned-party services used.
- The goods can be unambiguously identified and correctly classified (especially dual-use items).
- The exporter knows the end user and end use in the third country.
Without this evidence—or if provision is delayed—Customs will not release the goods from the EU. Extended verification may also cause unwanted vehicle delays.
Additional clarifications for business:
In comments to Cargonews concerning “Beltamozhservice,” Lithuanian Customs emphasized that from June 5, 2023 it did not impose extra sanctions on this company but simply reminded businesses that transactions with it are prohibited. Many EU carriers use “Beltamozhservice” for trailer swaps in Belarus; Customs urges operators to assess risks and avoid using services of an EU-sanctioned entity (Regulation 765/2006).
Between June 5 and 9—when stricter sanctions enforcement began—Lithuanian Customs blocked 370 vehicles that did not meet requirements or failed to present documentation, noting a trend of drivers arriving at checkpoints without papers, disrupting whole queues.
From July 3, 2023, certain goods transiting Russia and/or Belarus must be accompanied by a manufacturer’s declaration. The Customs Department published the list of dozens of applicable commodity categories here.
From June 5, 2023, Lithuania already applies enhanced controls. But statistical data show parallel imports of some goods into Russia and Belarus persist. Therefore, Customs requires manufacturer declarations for export and re-export procedures starting July 3—and at border checkpoints from July 17. The declaration must confirm:
- The manufacturer knows its buyer and seller and that the transaction will not violate sanctions.
- The manufacturer is aware the goods will transit Russia and/or Belarus and certifies no resale, processing, storage, or reloading (including trailer swaps) will occur.
- The manufacturer knows the end user and end use, and that sanctions conditions will be met.
Absent a valid declaration—or if authenticity is in doubt—Customs will refuse release and may contact the producer’s competent authorities to verify.
Five neighboring countries—Estonia, Latvia, Lithuania, Finland and Poland—have prepared joint practical guidelines for economic operators to detect and prevent sanctions circumvention. The recommendations help assess risks, identify vulnerable partners, and properly apply EU sanctions; the Lithuanian-language document is available here.
From September 11, 2023, Lithuania will require additional documents for exports initiated by entities from other EU member states (with or without a Customs representative). Under new rules—initially slated for September 4 but postponed to September 11—proof of payment for packaging and loading (invoices, payment receipts) must be submitted to Customs. These measures support enforcement of EU sanctions against Russia and Belarus (details here).
Lithuanian Customs is tightening transit controls on goods bound for third countries via Russia and Belarus, according to the Customs Department. “To prevent sanctions evasion, from November we are strengthening controls on goods imported into Lithuania and transiting via Russia and Belarus to third countries,” the statement reads. Customs will scrutinize classifications and “recommends detailed descriptions with supporting documentation,” the department noted. In July, Vilnius introduced stricter transit rules: exporters must provide a manufacturer’s declaration for 57 commodity groups, naming the exporter and third-country buyer and confirming no unloading, reloading or resale will occur in Russia or Belarus.
In mid-November, Lithuania expanded its list of dual-use goods restricted for export to third countries (details here, item 19).
Since December 3, certain documents must be filed via the iMDAS system; usage instructions (in Lithuanian) are available here.
Lithuanian Customs announced that from December 18 it will tighten control over (re)exports of sanctioned goods.