The current geopolitical scenario, aggravated by the conflict in Ukraine, has resulted in a framework of increasingly severe restrictions on exports from Italy to Russia.

With the approval of the EU’s 17th sanctions package, which came into force in May 2025, the list of banned goods has expanded further to include seemingly simple components such as screws, aluminium alloys and high-precision technology.

To this day, sending goods to Russia, whether temporarily or in outright transfer, requires meticulous care. European sanctions prohibit the export of advanced technologies, electronic components, industrial machinery and, in general, all goods considered to be ‘dual-use’, i.e. susceptible to both civil and military uses. In many cases, it is mandatory to include specific clauses in contracts prohibiting re-export to Russia, even when the goods are destined for third countries.

Food Machinery:

One of the few areas that still retain an operating margin is machinery for food and pharmaceutical production.

In these sectors, there are some exceptions, provided the goods are not considered strategic and do not contain restricted components, such as sensitive software or advanced electronic controls.

However, the assessment must be made on a case-by-case basis, with careful verification also of the end-user, who must have no links with the military or sanctioned companies.

Temporary exports: trade fairs and exhibitions:

Temporary exports, such as those for participation in trade fairs, exhibitions or demonstrations on Russian territory, are also subject to the same restrictions as final supplies.

Circular No. 27/2024 of the Customs and Monopolies Agency provides detailed indications on the temporary export regime and the subsequent duty-free reintroduction.

However, the obligation remains to apply for specific authorisations and to check carefully that the goods are not among those subject to prohibitions.

Operational Recommendations:

In such a complex environment, companies wishing to export to Russia need to take a number of key precautions:

• Carefully check EU restrictions by consulting the annexes to the regulations to see if the goods fall into the prohibited categories.
• Perform due diligence on customers and business partners, to avoid dealings with sanctioned entities or those related to military use.
• Include the ‘No Re-export to Russia’ clause in contracts, even if the customer is in a third country.
• Obtain any specific authorisations for temporarily exported goods, or for exceptional cases provided for by regulations.
• Avoid any technical collaboration, such as assistance, advice or installation related to prohibited goods.
• Contact specialised bodies such as Confindustria Emilia or legal consultants experienced in customs and international law.

Transit through third countries:

Some companies consider the possibility of exporting indirectly to Russia via third countries, such as Turkey, which maintains trade relations with Moscow. This is a theoretically viable route, but one that involves high risks.

It is essential to precisely structure the entire logistical and contractual flow, ensuring that there are no violations of EU or intermediary country regulations. Otherwise, the company could face serious penalties for illegal triangulation.

Exporting to Russia today is not impossible, but it is heavily regulated. In sectors such as food and pharmaceuticals, a few exceptions allow room for manoeuvre, but each transaction must be assessed very carefully. Staying up-to-date, planning precisely and relying on industry experts is the key to avoiding legal risks and ensuring full compliance with European regulations.

We at the Demix Group strongly support the development of innovative technological solutions for the food sector as well, offering support to companies operating in international markets, even in complex contexts such as exports to Russia, always in compliance with current regulations.

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