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SAIL Legal Position | EU Sanctions May 16th 2022

Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (the “Fifth Package”) has considerably extended the scope of restrictive measures that concern natural or legal persons, entities or bodies in Russia or making use of certain goods or services in Russia.

As a result of the Fifth Package, Council Regulation (EU) 833/2014, and more in particular Article 3c and 3k and the related Annexes, includes restrictive measures relating to certain lubricant related products and related services. The Regulation is mandatory law applying to all entities established within the European Union. A copy of the consolidated version, as it stands today, can be found here.

Following a detailed and comprehensive review, SAIL has established that its activities are in scope of certain provisions of the EU Fifth Package and has concluded to the existence of a legal impediment, resulting from the EU Fifth Package. On that basis (and as long as this legal impediment exists), it cannot any longer provide its services to Russian-origin lubricants manufacturers/marketers. The above also prohibits SAIL to purchase services for testing activities in Russia.

In case of changes to Council Regulation (EU) 833/2014, SAIL will decide on an appropriate course of action


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