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Where the EU falls short, and where it does not

· Helfen statt Blockieren editorial team

The EU adopts sanctions in quick succession, 21 packages against Russia alone. Yet it hardly enforces the protection of its firms against third-country sanctions: the Blocking Statute turns thirty on 22 November 2026, and the Commission receives on average 24 notifications a year. An assessment with both sides: where the EU fails, where it holds itself back and what works.

24notifications a year to the Commission under the Blocking Statute, since August 2018Commission, 2021
21sanctions packages against Russia by July 2026Commission
18 of 27states sent formal notices in July 2025 for not transposing the criminal law directiveeucrim
0uses of the Anti-Coercion Instrument as of January 2026Wikipedia, secondary source

The protection that rarely bites

On 22 November 2026 the Blocking Statute turns 30. It prohibits EU firms from complying with certain US sanctions and allows them to claim damages. In its 2021 consultation the Commission itself wrote that third-country sanctions with effect on others had caused significant damage to the EU economy and had “forced” some firms to withdraw from entire sectors. Since August 2018 it has received on average 24 notifications a year. Penalties are imposed by member states, each under its own law. The consultation closed in November 2021; we found no legislative proposal for reform in the sources read since then. In October 2026, after new US sanctions against the International Criminal Court, MEPs called for the statute to be applied; the Commission initially opted for talks (EU timeline).

What the statute protects and where it ends is set out in 30 years of the Blocking Statute. The finding here is a different one: the EU has created a second tool for the same purpose, the Anti-Coercion Instrument (Regulation (EU) 2023/2675, in force since December 2023). It too had not been used by January 2026, although it was seriously considered in 2025 in the tariff dispute with the United States and in January 2026 in the dispute over Greenland.

Many packages, one veto

By July 2026 the EU had adopted 21 sanctions packages against Russia. The latest, of 23 July 2026, brought 218 new listings, the highest number since the war started, bans transactions with more than 100 Russian banks and lists 27 companies in third countries, 14 of them in China. Every package needs the consent of all 27 member states. On 22 February 2026 Hungary announced it would block the 20th package until oil flowed again through the Druzhba pipeline; it was adopted on 23 April 2026. Unanimity makes sanctions credible once they are agreed, and vulnerable as long as one state uses them as leverage.

How much trade the sanctions on Russia cover

Share of EU trade with Russia before the 2022 invasion that is covered by restrictions, percent. Exports: 52 billion euros, imports: around 95 billion euros.

DirectionShare
EU exports to Russia58%
EU imports from Russia61%

Source: estimate by the European External Action Service, quoted in the European Court of Auditors newsletter 2/2025.

Do the packages work? The answer depends on what you measure. According to an estimate by the European External Action Service, the restrictions cover 58 percent of EU exports to Russia before the war and 61 percent of imports. The Russian state’s oil and gas revenues amounted to 7.5 trillion roubles from January to October 2025, according to the finance ministry, 21 percent less than a year earlier; the report cites lower oil prices, a strong rouble, tighter sanctions and wider discounts. According to the IMF, Russia’s economy grows by 0.9 percent in 2026, so it is not collapsing. In the working paper on Release 4, the Global Sanctions Data Base finds that trade with the sanctioning states fell by about a quarter, less than under earlier embargoes, because China, India and Türkiye stepped in (figures and detours).

Enforcement happens in 27 capitals

Sanctions are decided in Brussels; customs, supervisors and prosecutors in each state have to enforce them. So that circumvention does not move to wherever penalties are mildest, a directive with common minimum penalties has applied since 2024 (Directive (EU) 2024/1226). The deadline expired on 20 May 2025; in July 2025, 18 of the 27 states received letters of formal notice from the Commission. Whether trade sanctions work overall and whether loopholes are closed in time has been under audit by the European Court of Auditors since 2025; its report was not among the sources read as of 3 November 2026.

Caution that prevents more than the law does

Part of the damage comes not from prohibitions but from excessive caution: banks reject permitted payments because checking costs more than the business is worth. In January 2022 the European Banking Authority warned against such “unwarranted” de-risking. There is no count of cases in the EU. How this works in practice is described in Permitted and still blocked.

The EU’s own construction site: the single market

In 2024 the IMF calculated that barriers between EU countries act like a tariff of around 45 percent on goods and about 110 percent on services; between US states the figure for goods is about 15 percent. According to the IMF, income per head in Europe is around 30 percent below that of the United States, mainly because of lower productivity. Mario Draghi’s report of September 2024 put the additional investment need at 750 to 800 billion euros a year. Here Europe loses more prosperity than through any third-country sanction, and here it can act alone.

The single market still has borders

Barriers to trade within the EU, converted into an equivalent tariff, percent; for comparison, trade between US states. IMF estimate, rounded.

TradeTariff equivalent
EU, services110%
EU, goods45%
US between states, goods15%

Source: IMF, Alfred Kammer, speech on the Regional Economic Outlook for Europe, 14 Nov 2024 (“around 45 percent”, “about 110 percent”, US comparison about 15 percent).

Six EU tools and their record
InstrumentSincePurposeStatus November 2026
Blocking Statute1996protect firms from third-country sanctionsOn average 24 notifications a year to the Commission since August 2018; enforcement left to member states; review launched in 2021, no legislative proposal found
Sanctions on Russia2014, tightened from 2022raise the cost of the war21 packages; according to the External Action Service they cover 58 percent of former exports and 61 percent of imports
Criminal law for violationsdirective 2024, deadline May 2025same penalties in every stateJuly 2025: 18 states sent formal notices
Anti-Coercion InstrumentDecember 2023respond to economic pressurenot used as of January 2026, considered several times
Trade agreementsongoingopen marketsMercosur provisionally applied since May 2026; India negotiated, not yet signed
Single market1993free movement within the EUbarriers equivalent to a tariff of around 45 percent on goods, 110 percent on services (IMF)

Sources: Commission (2021 consultation, 21st package), eucrim, European Court of Auditors, Wikipedia on the Anti-Coercion Instrument (secondary source), Commission on India, IMF. Individual references below.

What works

Since 2022 the EU has held a common line on Russia over 21 packages, despite vetoes. It opens markets where others close them: the agreement with Mercosur has been provisionally applied since May 2026, and negotiations with India were concluded in January 2026. In 2020 it created, together with 15 other members, the interim arrangement for appeals in the WTO, which continues to work without the United States. And it has incorporated humanitarian exemptions into its sanctions regimes (see timeline).

The case of Cuba

Cuba shows both sides. The EU rejects the US embargo’s effect on third parties and has the Blocking Statute for that purpose. At the same time, on 18 June 2026 the European Parliament demanded the release of all political prisoners; Prisoners Defenders counted 1,351 in September 2026. In the UN vote on the embargo on 28 October 2026 (130 in favour, 17 against, 25 abstentions), EU states did not vote alike: Lithuania, Slovenia, Czechia and Hungary voted against, and ten states, including Germany, abstained.

Two readings

The case for the EU

  • Unanimity ensures that sanctions are carried by everyone; despite vetoes, the EU has adopted 21 packages.
  • Restraint in applying the Blocking Statute avoids conflict with the most important ally and protects firms from double pressure.
  • Common minimum penalties and listings in third countries show that the EU learns from circumvention.

The case against

  • A single state can delay packages and extract concessions, as happened in February 2026.
  • A protective law that is hardly enforced does not protect; the Commission itself describes the damage from third-country sanctions as significant.
  • The largest losses arise in the EU’s own single market, not from other states.

Check the numbers: daten/abruf.py downloads the IMF, World Bank and uncertainty series; the extracts are in daten/ergebnis_*.csv, values taken from reports in daten/werte_berichte.csv.

This analysis is information, not legal, tax or investment advice. It reflects the view of the editorial team, presents arguments from both sides and makes no forecast of its own. “Helfen statt Blockieren” is non-partisan.

Sources

All online sources accessed on 3 November 2026. Secondary sources are marked; the figures there come from the publisher named.

To the situation report Blockades and the world economy 2026