As with previous penalty packages, a transitional period applies to these energy products. Therefore, the extensive import of energy (crude oil, oil products, LNG, coal) through the port of Rotterdam is not (yet) affected by sanctions. This does however apply to the export and transhipment of containers. Shipping companies are transporting significantly fewer containers to and from Russia as a result of the war and sanctions.
62 million tonnes of the almost 470 million tonnes of transhipment in the port of Rotterdam is Russia-oriented (13%) (source: CBS). Many energy carriers are imported from Russia via the port of Rotterdam. Roughly speaking, 30% of crude oil comes from Russia, 25% of LNG and coal and 20% of oil products. Russia exports products such as steel, copper, aluminium and nickel through Rotterdam.
The measures of the European Union’s Sanctions Package 6, published on 3 June 2022, will apply from that date. This sixth package includes for instance a ban on:
- The import of crude oil and oil products
- Financing and insurance of transport of oil and oil products
- Export restrictions on chemical products that could be used for the manufacture of chemical weapons
A transitional period of six months applies to the import of crude oil via ports. A transitional period of eight months applies to the import of oil products via ports.
For the full text of the European Regulation: Publications Office (europa.eu).
Previous sanction packages have included a ban on access by vessels registered under the Russian flag to ports on the territory of the European Union (1).
For example, the fifth sanction package included a ban on:
- imports from Russia of coal and other solid fossil fuels
- access to EU ports for all Russian vessels
- entering the EU for Russian and Belarusian road hauliers
- the import of other goods such as timber, cement, fishery products and alcohol
- exports to Russia of aviation fuel and other goods
The fifth sanction package contains exemption provisions for certain types of cargo. Ships flying the Russian flag but falling under the exemption provisions can therefore still be admitted to the port. The exemption provisions cover cargoes such as oil and gas, refined oil products and some ores, pharmaceutical and medical products, agricultural and food products, products for civil nuclear applications and for ships on humanitarian grounds (2).
Apart from this package of sanctions, a list of natural persons and entities against whom restrictive measures have been imposed has been published by the European Union. This includes a number of ships. For these ships, certain exemption provisions apply (3).
The master, agent, shipowner and cargo owner of a Russian ship should ascertain whether any exemptions apply to the ship under which it can be admitted. The Harbour Master remains responsible for the implementation of the admission policy to the port.
(2) The exemption provisions are on pages 3 and 4 of the EU Regulation: Article 3ea, paragraph 5 a to e. It also refers to annexes with specific cargo numbers (GN numbers, listed in Annex XXII on page 33 and Annex XXIV on page 66).
(3) For the full text of the European Regulation, see: Publications Office (europa.eu). For an up-to-date overview of the European sanctions against Russia see: EU sanctions against Russia for invasion of Ukraine | European Commission (europa.eu)
Barely 10% of Rotterdam’s container transport is linked to Russia. The European Union has prohibited the export of a number of goods that can be used for both civilian and military purposes (dual use). That means container cargo with Russia as its destination will receive extra Customs inspections.
As far as cybersecurity of businesses is concerned, port of Rotterdam has FERM. The purpose of FERM is to encourage cooperation between companies in the port of Rotterdam and to increase awareness of cyber security risks. Currently, FERM has reported that the National Cyber Security Center (NCSC) has not yet had any concrete indications of cyber attacks impacting the Netherlands in relation to the war in Ukraine.
The Rotterdam Port Authority has not independently drafted any policies of its own in response to the war in Ukraine. Nor does the Port Authority have the authority to do something like impose restrictions on businesses. This is the responsibility of the Dutch government. The Port Authority supports the policies of the Dutch and European authorities. International rule of law and the right of self-determination of states are essential values that must not be compromised, as well as the notion of a level playing field on which Member States act.