How to notify the authorities of the use of an exemption to the restrictions on exports to Russia and apply for an export authorisation

The Ministry for Foreign Affairs gives additional instructions related to the sanctions and export control regulations concerning Russia, which entered into force on 26 February 2022 based on Council Regulation (EU) 2022/328.

The extensive export restrictions set in Article 2a of Council Regulation (EU) 833/2014, which were amended by Council Regulation (EU) 2022/328(Link to another website.) (Opens New Window)), contain certain clearly defined exemptions.

In accordance with its Article 2a, paragraph 3, the Ministry for Foreign Affairs must be notified of exports to Russia within 30 days of the first export but a separate export authorisation is not required when products are exported for

  1. humanitarian purposes or health emergencies or the urgent prevention or mitigation of an event likely to have serious and significant impacts on human health and safety or the environment, or as a response to natural disasters;
  2. medical or pharmaceutical purposes;
  3. temporary export of items for use of news media;
  4. software updates; or
  5. use as consumer communication devices.

The notification to the Ministry for Foreign Affairs is submitted using the form below. The form must be filled in electronically in a word processing program (in Finnish) and sent to RU.vienti.ilmoitus.UM@formin.fi no later than within 30 days of the first export event. The use of the exemptions must be mentioned both in the notification and in the customs declaration.

Please note that in the following cases, a separate notification or export authorisation is not required, but the use of exemptions must be mentioned in the customs declaration if the products are meant for

  1. ensuring cyber security and information security for natural and legal persons, entities and bodies in Russia except for the Russian government and undertakings directly or indirectly controlled by the government; or
  2. the personal use of natural persons travelling to Russia or members of their immediate families travelling with them, and limited to personal effects, household effects, vehicles or tools of trade owned by those individuals and not intended for sale.

If these exemptions do not apply and the product is included in Annex VII of Council Regulation (EU) 833/2014, which has been amended by Regulation (EU) 2022/328(Link to another website.) (Opens New Window), an export authorisation is required. During the transition period (before 1 May 2022), export authorisations can be requested if the contract has been concluded before 26 February 2022. The applicant must justify why exports should be accepted during the transition period. After the transition period (starting on 1 May 2022), an authorisation can only be granted in cases where the products are intended for the following uses:

  1. cooperation between the Union, the governments of Member States and the government of Russia in purely civilian matters;
  2. intergovernmental cooperation on space programmes;
  3. the operation, maintenance, fuel retreatment and safety of civil nuclear capabilities, as well as civil nuclear cooperation, in particular in the field of research and development;
  4. maritime safety;
  5. civilian telecommunications networks, including the provision of internet services;
  6. the exclusive use of entities owned, or solely or jointly controlled by a legal person, entity or body which is incorporated or constituted under the law of a Member State or of a partner country; or
  7. the diplomatic representations of the Union, Member States and partner countries, including embassies and other missions.

Both export authorisations and export authorisations for dual-use items are requested via the e-services of the Ministry for Foreign Affairs. For more information, please visit https://um.fi/applying-for-export-authorisation