Key takeaways
Russian origin uranium
Carriage to third countries permissible but more limited under UK than EU sanctions.
Containers for nuclear material
Restrictions apply to their use under UK but not EU sanctions.
Counterparty due diligence
Crucial for all cargos exported to or from Russia.
Trade from Russia to third countries for Russian-origin nuclear uranium products classified under cargo code HS 2844 continues, but is this permissible under UK and EU sanctions?
It appears generally so, but there is a potential issue with whether the containers that are classified under cargo codes HS 8609 00 10 (or HS 8609 00 90) and are needed to carry the nuclear material (or indeed other cargo) away from Russia, may be brought into Russia in the first place.
UK position
Under the UK sanctions framework, a voyage carrying Russian-origin uranium to a third country (ie not the UK, Isle of Man or Russia) raises prima facie restrictions because certain uranium products classified under cargo code 2844 are subject to specific trade sanctions. However, a statutory exemption exists where activities are necessary for the continued operation of a nuclear installation in a third country that was operational on 20 May 2026.
It is understood that, generally, appropriate containers are carried empty to Russia, and they then may be transported by other means around Russia to collect the uranium, before being packed with uranium products classified under cargo code 2844 to be carried by sea to third countries.
The containers used are probably those with cargo code 8609 00 10, which have an anti-radiation lead covering, for the transport of radioactive materials. It is also noted that containers with cargo code 8609 00 90 are more general in nature but are specially designed and equipped for carriage by one or more modes of transport
Containers with cargo codes 8609 00 10 and 8609 00 90 are designated as ‘vulnerable goods’ under UK sanctions. Their export, supply, delivery or making available for use in Russia, together with related financial, insurance and ancillary services, is therefore generally prohibited where a UK nexus exists.
This leads to the surprising conclusion that exported nuclear material from Russia is likely to not be subject to UK sanctions, but bringing empty containers into Russia to export the uranium to a third country is. Furthermore, bringing containers with cargo code 8609 00 90 into Russia would similarly be prohibited under UK sanctions.
EU position
The EU sanctions position is materially different. Current EU sanctions do not expressly prohibit the transportation of uranium products under cargo code 2844, nor containers that are classified under cargo code 8609 which would then be used for the carriage of the uranium out of Russia. However, separate EU export control, nuclear regulatory and Euratom safeguard considerations may arise, particularly where nuclear materials transit through EU territory.
UK sanctions position
Russia to a third country
The UK sanctions regime imposes prohibitions on the import, acquisition, supply, delivery, financing, insurance, brokering and technical assistance relating to Russian-origin uranium and uranium consigned from Russia. These restrictions extend not only to imports into the UK but also to the supply or delivery of uranium from Russia to third countries.
However, the regulations contain an important exemption for activities necessary for the continued operation of a nuclear installation in a third country, provided that the installation was operational on 20 May 2026. There also do not appear to be any restrictions on the use of (specialist) containers to carry the nuclear cargo from Russia to third countries.
Accordingly, where a uranium cargo is destined for, and necessary for the operation of, qualifying nuclear facilities in a third country that were operating on 20 May 2026, the voyage may fall within the exemption. If the exemption applies, related services, including insurance (subject to any exclusions within relevant policies) and financing that would otherwise be prohibited, may also be permitted.
Third country to Russia
The principal sanctions concern arises, perhaps surprisingly, from the containers that are classified under cargo codes 8609 00 10 (or 8609 00 90) and are brought into Russia to carry the uranium to a third country.
Under the UK Russia sanctions regime, such containers are listed as ‘vulnerable goods’.
The legislation prohibits:
export to Russia
supply or delivery to Russia from third countries
making such goods available to persons connected with Russia
making such goods available for use in Russia.
The prohibitions also extend to related insurance, financing, technical assistance and brokering services if there is a UK nexus.
As the containers would be transported from a third country to Russia, the vessel’s call at Russia (or by whatever means the containers get into Russia) is likely prohibited under UK sanctions wherever a relevant UK nexus exists, unless a licence is in place.
Practical consequences
The use of these containers may prevent participation by parties subject to UK jurisdiction, including insurers, reinsurers, financiers or service providers with a UK connection unless a licence is in place.
EU sanctions position
Russia to non-Russian country
Unlike the UK regime, the EU sanctions framework currently does not contain a general express prohibition on the transportation of uranium products falling within cargo code 2844 from Russia to non-Russian countries.
Non-Russian country to Russia
The EU position also differs materially from the UK's treatment of containers with cargo codes 8609 00 10 or 8609 00 90. Current EU sanctions measures do not specifically prohibit the import into Russia of containers classified under cargo codes 8609 00 10 or 8609 00 90.
EU export control and nuclear regulatory considerations
Although no direct EU sanctions prohibition has been identified, nuclear materials may still engage broader EU regulatory requirements.
In this regard, uranium and other nuclear materials can fall within the EU dual-use export control framework and the Euratom safeguards regime. Where cargos transit through EU territory or EU ports, additional obligations may arise, including:
customs controls
nuclear material accounting requirements
reporting obligations
national nuclear licensing requirements
Euratom safeguard measures.
Counterparty due diligence
As with all cargos exported to or from Russia or other high sanctions risks jurisdictions, comprehensive due diligence should still be completed on all parties involved to ensure that there are no sanctioned entities involved. This would include an assessment of ownership and control of an entity because sanctions exposure can arise through association with designated persons even where the entity itself is not listed.
Conclusion
The carriage of Russian-origin uranium products classified under cargo code 2844 to non-Russian (third) countries appears generally permissible under both UK and EU sanctions regimes. However, under the UK regime, this is principally due to the limited exemption for activities necessary for the continued operation of qualifying nuclear installations.
The key (UK) sanctions risk arises from a vessel’s call at Russia (or by whatever means the containers get into Russia) with containers classified under cargo codes 8609 00 10 or 8609 00 90. This is because these containers are designated as ‘vulnerable goods’ and their supply, delivery or making available for use in Russia may be prohibited where a UK nexus exists, absent an applicable licence. No equivalent restriction has been identified under current EU sanctions measures.
Comment
Uranium with cargo code 2844 continues to be exported from Russia for use in nuclear power facilities worldwide. Whilst such a voyage from Russia is generally capable of being performed lawfully, UK-connected parties should carefully assess the sanctions implications of bringing containers classified under cargo codes 8609 00 10 or 8609 00 90 into Russia and ensure appropriate licensing and counterparty due diligence are in place before participating in the trade.
Our Sanctions team advises on complex, multi-jurisdictional sanctions issues, licencing, insurance coverage and general sanctions compliance. Please get in touch to discuss how we can support you.
