Contracts predating the ban
Until when may a contract concluded before the ban be performed
A ban does not always cut a contract on the day it enters into force. The article that introduces it usually gives a window to complete contracts concluded earlier. Below are 4 such windows from the source texts, of which 4 are running today.
Contracts concluded before 2026-07-24 may be performed until 2026-10-25.
3bg. With regard to goods falling under CN codes 2603, 2604, 2607, 2616, 2817, 2819, 3803, 7001, 7002, 7003, 7004, 7006, 7008, 7009, 7011, 7013, 7014, 7015, 7016, 7017, 7018, 7020, 7901, 8707 and 8708, the prohibitions in paragraphs 1 and 2 shall not apply to the execution until 25 October 2026 of contracts concluded before 24 July 2026, or of ancillary contracts necessary for the execution of such contracts.
Codes covered: 2603260426072616281728193803700170027003700470067008700970117013701470157016701770187020790187078708
Source on EUR-LexContracts concluded before 2026-07-24 may be performed until 2026-10-25.
9f. With regard to the goods falling under CN codes 3803, 7006, 7008, 7009, 7011, 7013, 7014, 7017, 7018, 7020, 8707 and 8708, the prohibitions in paragraphs 1 and 2 shall not apply to the execution until 25 October 2026 of contracts concluded before 24 July 2026, or of ancillary contracts necessary for the execution of such contracts.
Codes covered: 380370067008700970117013701470177018702087078708
Source on EUR-LexContracts concluded before 2025-02-25 may be performed until 2026-12-31.
3ch. With regard to the goods falling under CN code 7601, the prohibitions in paragraphs 1 and 2 shall not apply to the execution from 26 February 2026 until 31 December 2026 of contracts concluded before 25 February 2025, or of ancillary contracts necessary for the execution of such contracts, for a total volume of imports into the Union during that period not exceeding 50 000 metric tonnes of such goods. —————
Codes covered: 7601
Source on EUR-LexContracts concluded before 2026-04-24 may be performed until 2027-01-25.
3bf. With regard to goods falling under CN code 7403 19 , the prohibitions in paragraphs 1 and 2 shall not apply to the execution until 25 January 2027 of contracts concluded before 24 April 2026, or of ancillary contracts necessary for the execution of such contracts.
Codes covered: 740319
Source on EUR-LexFrequently asked questions
May I complete a contract concluded before the ban entered into force?
Often yes, but only within the window written into the article itself, and only for contracts concluded before the cut-off date. The window runs from the date the ban applies and is usually one to six months. After it closes, performing the contract is a breach, even if the contract predates the ban.
Does the wind-down cover every code in the package?
Not always. In the 21st package Russia granted a period for all 25 new entries (Art. 3i(3bg)), while Belarus granted it for only 12 of them (Art. 1ra(9f)). The remaining 13 Belarusian entries apply immediately. That difference does not come from the press release, it comes from the paragraph itself.
What about ancillary contracts?
Wind-down paragraphs usually also cover ancillary contracts necessary for the performance of the main contract, for example transport or insurance. The condition is that the main contract was concluded before the cut-off date.
Where do these dates come from?
From the consolidated texts of the regulations on EUR-Lex and from amending acts that have not been consolidated yet. Every row below carries a quote from the act and a link to the source, so the date can be verified without taking our word for it.