Possible tightening of restrictions on goods

One of the most explicit proposals that has come to light is the tightening of restrictions on the export of consumer goods considered luxury goods, publicly promoted by some Member States, such as Sweden. Among the measures proposed is the elimination of the value threshold, which would extend the scope of the veto to a larger number of products, regardless of their price.

In parallel, an expansion of bans and controls on critical technologies and sensitive goods is being considered, with the aim of closing loopholes detected in previous packages and weakening the Russian industrial base linked to the war effort. This could translate into more product codes subject to prohibition or export licensing.

More designated entities and indirect export controls

Following the pattern of previous sanctions, an expansion of the lists of designated Russian persons and entities is also expected, which could block transactions even when the product is not expressly prohibited, by preventing the provision of goods, services or funds to sanctioned recipients.

The new package could also tighten controls on indirect exports to Russia via third countries, with a particular focus on indirect exports via third countries. In practice, this may entail increased user and end-use documentary requirements, stricter control of intermediaries and supply chains, and increased pressure to include and enforce contractual non-re-export clauses to Russia.

Possible restrictions to associated services

Another line of work identified is the extension of sanctions to certain services linked to sensitive goods, such as maintenance, technical assistance, training, engineering or software. This type of restriction usually accompanies product bans and can significantly affect existing contracts and after-sales activities.

Planned calendar

According to available information, the approval of the 20th package is planned for February 2026, probably around the 24th, coinciding with the fourth anniversary of the Russian invasion of Ukraine.

Preparatory work and internal discussions will continue until the end of February, with formal approval by the EU Council being required.