On 23 April 2026, the European Union adopted Council Regulation (EU) 2026/506, introducing another package of sanctions against Russia. The regulation expands existing restrictions, strengthens anti-circumvention measures, and introduces new compliance obligations for businesses operating internationally.
Key changes
- Expansion of the Sanctions List
The regulation adds 60 additional entities to Annex IV of Regulation 833/2014. These organizations are considered to support Russia’s military-industrial complex or facilitate the circumvention of export controls. Several of the newly listed entities are located outside Russia and are alleged to assist in the supply of restricted technologies and components. - Stronger Anti-Circumvention Measures
This is the most interestling point also in reagard of the EAC Certification. Significant efforts have been undertaken to prevent the re-export to Russia of Union-origin dual-use goods and technology, including the Common High Priority (CHP) items listed in the relevant Annexes to Regulation (EU) No 833/2014.The EU named explicitly the Kyrgyz Republic as a country with a high risk of circumvention, through the subsequent sale, supply, transfer or export of the goods from the Kyrgyz Republic to Russia.
The EU has added CN code 8457 10 (machining centres for working metal) and CN code 8517 62 (equipment for the reception, conversion and transmission of data, including switching and routing apparatus), as well as the Kyrgyz Republic, to the list of high-risk goods and countries.
The decision was based on a significant increase in trade flows since February 2022:
- Imports of these goods from the EU to Kyrgyzstan during the first ten months of 2025 were approximately 800% higher than before the war.
- During the same period, exports of these goods from Kyrgyzstan to Russia increased by around 1,200%.
According to the EU, these trade patterns indicate a substantial risk that the goods are being re-exported to Russia, thereby circumventing existing sanctions.
As these products can contribute to Russia’s military, technological, defense, and security capabilities, the EU introduced additional restrictions to prevent sanctions evasion through third countries.
- Additional Export and Technology Restrictions
The regulation expands restrictions on a range of products and technologies that could contribute to Russia’s military, technological, or industrial capabilities. The affected goods include certain machine tools, microelectronics, drone-related components, maritime equipment, and other industrial products. - New Service Restrictions
The EU has extended the list of prohibited professional services to include managed security services, further limiting the provision of IT and cybersecurity-related support to Russian entities. This prohibition becomes applicable from 25 May 2026. - Maritime and Energy Measures
The regulation introduces additional controls on the transport of Russian crude oil, petroleum products, and certain vessels involved in high-risk shipping practices. It also extends restrictions relating to natural gas condensates and certain energy-related products. - New Reporting and Due-Diligence Requirements
Companies involved in international trade, logistics, finance, and compliance must pay increased attention to:- Screening counterparties against updated sanctions lists.
- Verifying ownership and control structures.
- Reviewing payment mechanisms and alternative settlement arrangements.
- Assessing supply chains for possible sanctions circumvention risks.
Limited Exceptions
The regulation maintains certain exemptions for:
- Humanitarian activities.
- Medical and pharmaceutical supplies.
- Agricultural and food products.
- Certain civil nuclear activities.
- Specific public transport maintenance projects
Practical Impact for Businesses
Companies trading with Russia, Belarus, Central Asia, the Caucasus, Türkiye, the UAE, China, or other regions frequently used as transit hubs should carefully review their compliance procedures. The new rules increase the EU's focus on sanctions circumvention and require greater scrutiny of supply chains, intermediaries, payment flows, and end users.
EAC Certification aspects
Many companies began applying for EAC certificates in Kyrgyzstan instead of Russia. This approach was considered highly attractive because certification bodies in the Kyrgyz Republic often offer significantly lower prices, faster processing times, and in some cases issue certificates without proper sample testing, production audits, or full product inspections.
As a result, the process was both cost- and time-effective.
Kazakhstan was the first country to raise concerns and question the validity of certificates issued in Kyrgyzstan. The background to this development and our response are explained in the article “Kazakhstan announces restrictions on EAC certificates from Kyrgyzstan – what companies need to know now”.
Since February 2026, Russia has also introduced stricter measures regarding foreign-issued certificates. Rosakkreditatsiya has started suspending the validity of documents issued by certain Kyrgyz certification bodies. More information can be found in our article "“Grey certificates from Kyrgyzstan: market cleanup has begun”.
Schmidt & Schmidt provides a legally compliant solution via Kazakhstan. As an EAEU Member State, Kazakhstan is authorized to issue EAC Certificates and EAC declarations. Through our local offices, we ensure that all conformity assessment processes are carried out in compliance with European and US sanctions regulations while enabling our clients to access the EAEU market.
Conclusion
Regulation (EU) 2026/506 represents another significant tightening of EU sanctions against Russia. The main focus is no longer only direct exports to Russia but also the prevention of indirect supply routes, alternative payment mechanisms, and the use of third-country intermediaries. Businesses involved in international trade should reassess their sanctions compliance programs to ensure continued compliance with EU law.
How we can support you
Schmidt & Schmidt offers comprehensive support:
- Review of existing certificates for potential risks
- Consulting on the selection of reliable certification bodies
- Complete new-certification of your products in Kazakhstan
- Assistance with customs procedures and market surveillance issues
Contact us — we will advise you individually and help secure your supply chain.
What is an EAC Certification?
In our video, we explain what an EAC Certification is and how and where to certify or declare your products for the introduction on the EAEU market.
The EAC Certification and the EAC Declaration are complex procedures that attest your products the conformity with the technical regulations of the EAEU and require a lot of know-how. Schmidt & Schmidt will support you with the certification of your products for the EAEU market.
How can we help?
In this rapidly changing regulatory environment, Schmidt & Schmidt offers comprehensive support for exporters to the EAEU countries. Our service portfolio includes EAC certification, customization to specific product categories and tailored solutions to comply with the technical and legal requirements of these markets. We are committed to making it easier for companies to enter and expand in these regions by providing the most up-to-date information and guidelines.
Technical expertise, care and accuracy in the preparation of documents are the prerequisite for problem-free distribution and use of products, machines or systems in the EAEU territory. The technical documentation must also be written in Russian or in the official language of the respective member country in which the product is to be sold or used.
In order to avoid any problems, we will be happy to help you create new technical documents or check existing documents for completeness and linguistic and terminological correctness in Russian.
Thanks to their many years of experience, our experts can also provide you with specific industry knowledge from plant engineering, mechanical engineering, metal construction, measurement technology, electrical engineering, automation technology, medical technology, food technology and the furniture industry.
