In view of Council Regulation (EU) 2022/263 on restrictive measures in response to the recognition of non-government controlled areas in the Donetk and Lugansk oblasts of Ukraine and the ordering of armed forces in these areas, ANAF warns of restrictions on exports and imports.

As regards import formalities, according to the provisions of Article 2, they are prohibited:

(a) the import into the European Union of products originating in the specified territories;

(b) the provision, directly or indirectly, of financing or financial assistance and of insurance and reinsurance services in connection with the importation of the products referred to in (a).

(2) The prohibitions in paragraph 1 shall not apply in respect of:

(a) the execution, until 24 May 2022, of commercial contracts concluded before 23 February 2022 or ancillary contracts necessary for the performance of those contracts, provided that the natural or legal persons, entities or bodies intending to perform the contract in question have notified the competent authority of the Member State in which they are established, at least 10 working days in advance, of the activity or transaction in question;

(b) products originating in the specified territories which have been submitted to the Ukrainian authorities for examination, for which compliance with the conditions conferring preferential origin has been checked and for which a certificate of origin has been issued in accordance with the EU-Ukraine Association Agreement.

With regard to import operations, the notification pursuant to Article 2 (2) (a) for exemption from the provisions of Article 2 (1) (a) shall be sent by the importing economic operator, only in electronic format, to the Directorate General of Customs, at the following e-mail address: vama@customs.ro, together with a copy of the commercial contract concluded before 23 February 2022, and, where applicable, copies of the ancillary contracts necessary for the execution of the contract in question. 

For more details on the format of the notification please consult the official document sent by ANAF by clicking on the following link: ANAF notification on imports and exports.

Regarding the export part, according to the provisions of art.4, the sale, supply, transfer or export of the products and technologies listed in Annex II is prohibited:

(a) to any natural or legal person, entity or body in the specified territories; or

(b) for use in the specified territories.

Annex II includes certain products and technologies suitable for use in the following key sectors:

(i) transport;

(ii) telecommunications;

(iii) energy;

(iv) prospecting, exploration and production of oil, gas and mineral resources

2) Prohibits:

(a) the provision, directly or indirectly, of technical assistance or intermediation services related to products and

technology listed in Annex II or related to the provision, manufacture, maintenance and use of such products and technology.

technologies to any natural or legal person, entity or body in the specified territories, or for

use in the specified territories;

(b) the provision, directly or indirectly, of financing or financial assistance related to the goods and technology

listed in Annex II to any natural or legal person, entity or body in the specified territories or for the purpose of

for use in the specified territories.

(3) The prohibitions in paragraphs (1) and (2) are without prejudice to the execution until 24 August 2022 of an obligation arising from

a contract concluded before 23 February 2022 or ancillary contracts necessary for the performance of such contracts.

contracts, provided that the competent authority has been informed at least five working days in advance.

And in this case, pursuant to art.4 paragraph 3 for exemption from the provisions of art.4 paragraphs 1 and 2, is transmitted by the economic operator sender, only in electronic format, to the Directorate General of Customs, at the email address: vama@customs.ro, together with a copy of the commercial contract concluded before February 23, 2022, and if necessary, copies of the ancillary contracts necessary for the execution of that contract. 

For details on the specifics of the information please consult the official ANAF document found at this link: ANAF notification on imports and exports.

For more details on the restrictions imposed by the European Union, given the current circumstances, please consult the following link: COUNCIL REGULATION (EU) 2022/263 of 23 February 2022 concerning restrictive measures in response to the recognition of non-government-controlled areas in the Donetsk and Lugansk oblasts of Ukraine and the subsequent decision to deploy Russian troops in these areas.