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Estoniae-MTA

EMTA corrects the Estonian date for a Russia-sanctions wind-down clause

The authority says Article 3i(3bg) uses 25 October 2026 for specified goods and pre-24 July contracts; the Estonian version had incorrectly stated 25 August.

By Taxxa AI OyPublished 26 August 2026

Financial Sector & Markets Tax

Industry: Across industries

Estonia’s Tax and Customs Board says the correct wind-down date in Article 3i(3bg) of the Russia-sanctions regulation is 25 October 2026Emta. Its guidance flags an error in the Estonian-language amendment, which stated 25 August 2026. Traders relying on this particular clause should check both the goods classification and the contract date against its conditions.

The clause concerns the execution of contracts concluded before 24 July 2026, together with ancillary contracts necessary to execute them. For the specified goods, it disapplies the prohibitions in Article 3i(1) and (2) for that execution until the stated October dateEmta. Those limitations are part of the provision: the corrected date should be applied together with the relevant contract and commodity conditions.

The CN codes listed are 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 8708Emta. Customs teams should check the actual classification against that list before relying on the clause.

The authority reproduces the English-language provision, which already uses 25 October 2026, and links Council corrigendum document 12435/26, dated 26 August 2026. That document identifies the language concerned as EstonianEmta and sets out replacement wording changing the August date to October. It concerns the insertion of Article 3i(3bg) into Regulation No 833/2014 by Council Regulation 2026/1848Emta.

The Council document describes the procedure for an obvious error in one language version and gives member states eight days to submit observations. The practical guidance from EMTA is that the date in the Estonian clause must be read as 25 October 2026Emta.

Trade-compliance teams should retain the contract date and commodity classification with their assessment of whether the wind-down applies. EMTA also advises consulting both the consolidated sanctions regulation and the latest amendment to obtain the full picture of the restrictions. The correction addresses the date in this specified clause; the surrounding conditions remain essential to its use.

Check the listed CN codes and pre-24 July contract condition before relying on the corrected wind-down date.

Sources