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No Russia clause and end-user statement

Article 12g of Regulation 833/2014 requires a contractual ban on re-export to Russia for listed goods. Fill in the data below and print a ready-to-sign document. The preview updates live.

Document data

End-user statement and the “No Russia” clause

Basis: Article 12g of Council Regulation (EU) No 833/2014 (Russia); accordingly Article 8g of Regulation (EC) No 765/2006 (Belarus).

Parties

Exporter: [Exporter]

Buyer / Importer: [Buyer / Importer]

End user: [Buyer / Importer]

Goods

[goods description]

1. No re-export to Russia clause (Art. 12g)

The Buyer/Importer ([Buyer / Importer]) shall not sell, export or re-export, directly or indirectly, to the Russian Federation or for use in the Russian Federation any goods supplied under or in connection with this Agreement that fall under Article 12g of Council Regulation (EU) No 833/2014. This clause constitutes an essential element of the contract.

2. End-user and end-use statement

I declare that the end user of the goods listed above is [Buyer / Importer], that the goods will be used as intended and will not be re-exported to the Russian Federation or the Republic of Belarus, nor used to circumvent European Union restrictive measures. I undertake to inform the exporter without delay of any change of end user or intended use.

3. Consequences of a breach

A breach of the above obligations entitles the exporter to terminate the contract and to pursue adequate legal remedies. A breach may give rise to criminal and administrative liability under EU and national law.

[place], [date]
Exporter signature
Buyer / end-user signature

Reference template, not legal advice. The operator sets the final wording of the clause so that it meets the requirement of Article 12g; it is recommended to mark it as an essential element of the contract. Verify the scope of goods covered by Article 12g (Annexes XI, XX, XXXV, XL) in the current version of the regulation on EUR-Lex.

The No Russia clause from Article 12g, what you should know

What the Article 12g obligation is

Article 12g of Regulation (EU) 833/2014 introduces the so-called No Russia clause. When selling, supplying, transferring or exporting certain sensitive goods to a third country, the EU exporter must contractually prohibit the counterparty from re-exporting those goods to Russia or for use in Russia. The contract should also provide adequate remedies for a breach and a duty to inform the exporter without delay.

When the obligation applies

The clause covers listed categories of sensitive goods, among others from Annexes XI, XX and XXXV and high-priority items, supplied to partners outside the EU. It does not apply to sales within the EU or to partners from the countries listed in Annex VIII. The starting point is always the CN code, so first establish whether your goods fall within the covered categories.

How to apply the clause step by step

  1. Establish the CN code of the goods and check its status in the tool.
  2. Check whether the goods fall within the categories covered by Article 12g.
  3. Generate the clause and the end-user statement below.
  4. Include the provision in the contract and obtain the counterparty signature.
  5. Archive the document together with the CN code verification report.
Check a CN code Exporter obligations 2025

Frequently asked questions

What is the No Russia clause (Article 12g)?

It is a contractual obligation from Article 12g of Regulation (EU) 833/2014. When selling, supplying or exporting listed sensitive goods to a third country, the EU exporter must contractually prohibit the buyer from re-exporting those goods to Russia or for use in Russia, and provide an adequate remedy for a breach.

Which goods does the obligation cover?

Sensitive categories listed in the regulation, in particular advanced technology and firearms items from Annexes XI, XX and XXXV and common high-priority items, for example aviation goods and goods listed in Annex XL. Check the CN code of your goods first, the clause applies to the listed categories, not to every export.

Does the clause apply to sales within the EU?

No. Article 12g concerns sales, supply, transfer or export to a third country, that is outside the EU. It does not apply to partners in EU member states or in partner countries listed in Annex VIII to the regulation.

How do I apply the clause in practice?

Add a written provision to the contract prohibiting re-export to Russia, with a remedy and a notification duty for a breach. The generator below produces a ready-to-sign clause together with an end-user statement. Keep the signed document with the CN code verification report as proof of due diligence.

Is the end-user statement mandatory?

It is not always required outright, but it is a strong element of due diligence. A refusal to sign it or inconsistent information about the destination is a red flag that should be investigated before shipping.

Informational content based on Regulation (EU) 833/2014. It does not constitute legal or customs advice. The binding source is the text of the act in EUR-Lex. The scope of goods covered by Article 12g changes with each sanctions package, always verify the current version.