Lithuanian Customs will increase its focus on the export and transit control of goods transported to third countries via Belarus and Russia.
According to Lithuanian customs officials, there has been a growing number of attempts to transport goods using “suspicious routes.” For example:
— Goods from EU countries such as Slovakia or the Czech Republic—both neighboring Turkey—are being transported to Turkey through Lithuania’s border with Belarus or Russia.
— Goods from Germany or Estonia declared for delivery to the UK or other third countries (such as South Korea, Thailand, or the UAE) are being routed through the Medininkai checkpoint on the border with Belarus.
— A passenger car from Germany, declared for export to Kazakhstan, is being routed through the Kibartai checkpoint at the border with Russia’s Kaliningrad region.
Lithuanian Customs has reasonable grounds to suspect that the final destination of such goods is Russia and that these routes are chosen in an attempt to circumvent sanctions. In line with the European Commission’s guidance—specifically Article 12 of Council Regulation No. 833/2014—national authorities must not allow the export of goods if there are reasonable grounds to believe that such actions are intended to bypass restrictions. Lithuanian Customs has therefore stated that if a route through Belarus or Russia is deemed illogical or economically unjustifiable, the goods will not be cleared and the sender will be advised to use a different route and a different customs office within the EU.
In light of the atypical growth in trade with certain third countries and to prevent potential sanctions evasion, Lithuania is tightening controls on restricted goods.
New rules, effective from June 5, 2023, apply to goods exported to third countries via or transiting through Belarus and/or Russia. Businesses are advised to carry out due diligence before exporting sanctioned goods or providing logistics or customs services, and to ensure that goods transiting through Russia and/or Belarus are not destined for use in those countries, nor sold or delivered to any physical or legal entity in Russia or Belarus.
Lithuanian Customs will require additional proof that:
— The goods will not be sold and ownership will not change after export from the EU.
— Transit through Russia and/or Belarus is only part of a journey that begins and ends outside these countries.
— During transit, there will be no resale, processing, storage, or transfer of the goods to another vehicle, including trailer swaps, and no services from sanctioned parties will be used.
— The goods can be clearly identified to ensure proper classification and determine that they are not dual-use items.
— The exporter knows the final user and intended use of the goods in the third country.
Without the required documentation or in the case of delays, Lithuanian Customs will not clear the goods for export. Longer verification periods may also lead to unwanted delays for transport vehicles.
Additional clarification for businesses:
In a comment to Cargonews regarding “Beltamozhservice,” Lithuanian Customs confirmed that while stricter inspection measures for restricted exports were introduced on June 5, 2023, no new sanctions were imposed on this company. However, businesses were reminded that dealings with Beltamozhservice are prohibited under EU sanctions (Regulation 765/2006). Since many EU carriers use this company for trailer swaps in Belarus, businesses operating there should assess the risks and avoid using sanctioned service providers.
Between June 5 and June 9, 2023, Lithuanian Customs did not release 370 vehicles that either failed to meet the stated conditions or lacked necessary documentation.
Starting July 3, 2023, goods transported from Lithuania via Russia and/or Belarus must be accompanied by a manufacturer’s declaration. The list of affected product categories is published by the Lithuanian Customs Department.
This requirement is part of Lithuania’s broader effort to ensure transparency in supply chains and prevent parallel imports into Russia or Belarus. The declaration must be submitted:
— From July 3 for exports and re-exports
— From July 17 at border customs checkpoints
The declaration must confirm that:
- The manufacturer knows the seller and buyer of the goods and has no reason to believe the transaction would violate sanctions.
- The goods will only transit through Russia and/or Belarus without being resold, processed, stored, or transloaded, including trailer swaps.
- The manufacturer knows the final user and use of the goods in the third country, and is confident that the goods will not be used in violation of sanctions.
If this document is not provided, Lithuanian Customs will not allow the goods to leave the EU. In case of doubt, the authenticity of the document will be verified with the competent authorities of the producer’s country.
Five bordering countries—Estonia, Latvia, Lithuania, Finland, and Poland—have prepared joint practical guidelines to help economic operators detect and prevent sanctions evasion. The guidelines explain how to perform proper risk assessments and identify vulnerable clients or partners. (Available in Lithuanian at the provided link.)
Lithuanian Customs will apply stricter checks for export declarations filed by entities from other EU member states. From September 11, 2023 (postponed from September 4), exporters must submit invoices and payment confirmation documents for packaging and loading services. This is part of Lithuania’s implementation of EU sanctions against Russia and Belarus.
As of November, Lithuania has enhanced its control over transit cargo destined for third countries via Russia and Belarus. Customs officials emphasize the need for precise product classification and documentation. In July, the government listed 57 product categories that now require a manufacturer’s declaration confirming the goods will not be unloaded, transshipped, or resold while in transit.
In mid-November, Lithuania expanded the list of dual-use goods whose export to third countries is restricted (see point 19 of the updated regulation).