15+15 Webinar: Russian coal – sanctioned or back in business?

  • 28 September 2022
  • 28 September 2022
  • Online
  • Henriette Dybkær
  • hdy@bimco.org

Anders Fournais, Partner with HAFNIA LAW FIRM LLP in Copenhagen provides insight and takes you through the minefield of Russian sanctions. 

The 5th sanctions package adopted by the EU enforced an embargo against Russian coal. The sanction under Article 3j(1) of EU Council Regulation No 833/2014 prohibits the purchase, import, or transfer into the Union of Russian coal with a winding down period that lapsed on 10 August. On the face of Article 3j(1), the prohibition is limited to trade into the EU and so the market kept fixing coal destined for third countries. 

On 10 August 2022, at the stroke of a pen, the EU Commission issued a guideline saying that all trades in Russian coal are banned regardless of the ship’s destination, and that insurance (such as P&I cover) would contravene the sanctions. On 19 September 2022, the EU Commission issued further guidelines, back-pedalling. Is coal now back in business? 

  • Guidance on coal trading/transport – what is legal and what is not?
  • Limits to the EU Commission’s competence – can the Commission change the law by issuing a guideline? 
  • Should we expect new sanctions?


This 30-minute webinar begins at 14:00 CEST (12:00 UTC)


15+15 weekly webinars are a 30 minute webinar which includes a 15-minute presentation followed by a 15-minute Q&A