- within International Law, Coronavirus (COVID-19) and Environment topic(s)
- in Asia
On 23 October 2025, the Council of the European Union has adopted its 19th package of sanctions1 targeting Russia, marking a significant development for the European energy sector. The latest measures include – for the first time – a phased ban on the import of Russian liquefied natural gas ("LNG") into the EU. This follows the Council's recent endorsement of a proposed Regulation aimed at phasing out all Russian gas imports by 2028, including both pipeline and LNG deliveries.
According to the EU, Russian gas continues to represent an estimated 13% of the EU's gas supply, amounting to more than EUR 15 billion annually. The new measures aim to close this remaining dependency by establishing clear legal deadlines for the termination of Russian gas imports and enhancing regulatory oversight for all gas entering the EU.
LNG import ban – scope and timeline
The most notable energy-related measure in the 19th package is the introduction of a phased ban on Russian LNG imports:
- Short-term contracts must be terminated within six months (by April 2026);
- Long-term contracts must end by 1 January 2027 – a full year ahead of the Commission's original REPowerEU roadmap.
Until now, Russian LNG had largely escaped direct sanctions despite growing political pressure. This step is therefore seen as a milestone in the EU's energy decoupling efforts, particularly given Russia's continued LNG deliveries via European ports. The ban is expected to affect a limited but growing portion of residual Russian energy flows into Europe, particularly in Member States without pipeline infrastructure.
Related measures: shadow fleet, reinsurance, and market access control
In parallel, the Council has introduced additional restrictions targeting logistical and financial channels supporting Russian energy exports. These include:
- The designation of 117 additional vessels linked to Russia's so-called "shadow fleet," bringing the total number of vessels listed under EU sanctions to 557. These tankers, typically used to circumvent oil price caps, are now subject to EU port access bans and service restrictions.
- A ban on reinsurance for vessels linked to the shadow fleet, as well as for aircraft previously used by Russian operators.
- The listing of maritime registries operating under flags of convenience from Aruba, Curaçao, and Sint Maarten, as well as Litasco Middle East DMCC, a UAE-based energy company linked to Lukoil.
Sanctions on energy companies in third countries
For the first time, the EU has also listed non-EU entities for their role in facilitating Russian oil exports. This includes:
- Two Chinese refineries – Liaoyang Petrochemical and Shandong Yulong Petrochemical;
- One Chinese trading company – Chinaoil, the Hong Kong-based trading arm of PetroChina.
These listings reflect growing efforts to enforce EU sanctions extraterritorially and may have knock-on effects for international energy trade flows and compliance due diligence.
EU draft Regulation on phasing out Russian gas
The new sanctions package builds on the Council's recent endorsement ofdraft Regulation (COM(2025) 828) to phase out Russian gas imports. Although the legislative text remains subject to trilogue negotiations with the European Parliament, the proposed Regulation outlines the following measures:
- A full ban on new Russian gas import contracts from 1 January 2026;
- Transition periods for existing contracts:
- Short-term contracts (concluded before 17 June 2025): permitted until 17 June 2026;
- Long-term contracts: permitted until 1 January 2028;
- Contract amendments: permitted only for narrowly defined operational reasons, with no increase in volume – except for limited flexibilities for landlocked Member States affected by supply route changes;
- Prior authorisation requirements for both Russian and non-Russian gas imports, including:
- Disclosure of contract terms, volumes, and amendments;
- Documentation proving the share of Russian origin in mixed LNG cargos.
Together, these developments indicate an accelerated timeline for decoupling from Russian gas and LNG, with direct consequences for gas contracting, infrastructure planning, and risk assessment across the EU.
Looking ahead
Implementation of the LNG import ban and related measures will require further clarification – particularly regarding reporting obligations, contract wind-down processes, and compliance mechanisms at Member State level.
Stakeholders in the energy sector should closely monitor the evolution of both the sanctions package and the legislative phase-out of Russian gas, especially in light of its potential implications for offtake arrangements, reinsurance contracts, and shipping operations.
Footnote
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
