The EU's current sanctions policy

At the end of last year, there was a rise in cases of personal belongings being seized from Russian citizens flying out of European Union ("EU") countries: laptops, phones, jewellery, cosmetics and clothing.

In response, the Russian Ministry of Foreign Affairs published a warning to Russian citizens on its official website, recommending that they refrain from travelling to Germany unless absolutely necessary (see Sources, item 1).

According to the Ministry, Germany has de facto become a "zone of lawlessness" for Russian citizens, and cases of alleged violations of the "sanctions regime" are not examined objectively and comprehensively.

Enquiries from the Russian Embassy in Germany and the Russian Consulate General in Bonn about detentions and confiscations are ignored.

The Russian Ministry of Foreign Affairs strongly recommends that Russian citizens refrain from travelling to Germany unless absolutely necessary.

The Russian Consulate General in Bonn has also published recommendations on its official website for Russian citizens planning to travel to EU countries (see Sources, item 2).

We would particularly stress that being a private individual or declaring that goods are for personal use does not exempt anyone from sanctions restrictions: even a single item intended for personal use or as a gift is prohibited if it is on the relevant sanctions list.

Value thresholds apply to luxury goods (clothing, footwear, bags and jewellery if the unit value exceeds EUR 300; consumer electronics (phones, headphones, computers, etc.) if the unit value exceeds EUR 750; musical instruments if the unit value exceeds EUR 1,500; and others).

Our case

One C Cases client also fell foul of the so-called "sanctions regime": at the end of 2025, the client had personal belongings seized when departing from Stuttgart airport.

Just before boarding a Stuttgart–Istanbul flight, the client was detained and searched by officers of the Stuttgart Main Customs Office. The reason for the search was the answer "Russia" to the customs officers' question about which country's passport the passenger was holding.

Following the search (which lasted about an hour, so all flights were missed), the German customs officers seized items the Russian citizen had previously bought in the UAE and drew up the following documents: a seizure report (Sicherstellungsprotokoll) and a document on the provision of security and the appointment of an authorised recipient of correspondence (Sicherheitsleistung und Zustellungsvollmacht) (together, the "Documents").

As it later turned out, the Documents stated that the individual was suspected of exporting luxury goods from the EU to Russia, allegedly contrary to one of the EU's "sanctions" regulations, namely Regulation (EU) No 833/2014 of 31.07.2014 (the "Regulation"). In response, the C Cases team launched its own investigation to protect the rights of the client, who had been discriminated against in the EU on grounds of nationality, in direct breach of Article 21 of the EU Charter of Fundamental Rights, Article 18 of the Treaty on the Functioning of the European Union and Article 3 of the German Basic Law.

The official position and actions of the Stuttgart Main Customs Office:

Under Article 3h(2a) of the Regulation, luxury goods (Luxusgüter) means any goods worth more than EUR 300 (unless otherwise provided in Annex XVIII to the Regulation). Under Article 3h(2) of the Regulation, it is prohibited, with respect to luxury goods, for any Russian natural or legal person or state body to:

— sell;

— supply;

— transfer;

— export.

Please note that the Regulation contains a list of goods that may not be imported into the EU and a list of goods that may not be exported from the EU. Luxury goods appear only on the list of goods that may not be exported from the EU.

As a result, you may be able to bring a luxury item (as a rule, goods worth more than EUR 300) into the EU lawfully but not take it out (the customs authorities may treat this as exporting luxury goods from the EU to Russia or, for example, as transit (der Transit)). As a consequence, the customs authorities may at their discretion seize Russian citizens' personal belongings.

It is also important to bear in mind that detentions and searches take place shortly before departure, so the detained Russian citizen finds themselves in a stressful situation: the risk of missing the flight, a search of personal belongings in front of others, communication in a foreign language without an interpreter, and documents in German (if a Russian translation is provided at all, it is only at the very end, for signature, and copies of the documents may not be handed over). As a result, the Russian citizen flies out (often buying new tickets) without their belongings, having signed under psychological pressure documents whose content they do not know.

Recommendations from the C Cases team

To avoid such situations, the C Cases team recommends:

• carrying receipts showing that you bought the items outside the EU;
• explaining that the items were bought and used exclusively for personal purposes in everyday life, and stating that they have been used repeatedly, even if they were bought recently;
• drawing attention to the quantity and composition of the items being seized (for example, 1 pair of shoes in your size rather than 10 pairs of identical shoes, which might suggest an intention to resell);
• drawing attention to how insignificant the excess over the value threshold is.

If the customs authorities nevertheless draw up documents seizing items on suspicion of a breach of the EU sanctions regime, the C Cases team recommends paying particular attention to the following when signing them:

• The document may name a person whom, by signing, you authorise to receive correspondence on the case on your behalf (in our case, this was an official representative of the Stuttgart District Court (Amtsgericht Stuttgart));
• the document may state that you were assisted with translating the documents;
• the document may state that you handed over the items voluntarily.

The deadline for challenging the documents and the confiscation is 1 month from the date they were issued; objections (einen Einspruch einlegen) should be filed with the customs office that issued them. If the objections are rejected, you may challenge the customs authorities' actions in court (eine Klage einreichen).

When challenging the customs authorities' actions, we recommend:

• sending a request for information about your case to the person supposedly authorised to receive correspondence (in our case, to the official email of the Stuttgart District Court (Amtsgericht Stuttgart): poststelle@agstuttgart.justiz.bwl.de). You may be surprised to find that the person authorised to receive correspondence on your behalf no longer works at the organisation, and you will have to arrange with other representatives of the organisation for correspondence to be sent to you;
• sending a written request to the Central Information Office of the Customs Administration (Zentrale Auskunft der Zollverwaltung) asking for clarification of the provisions of the Regulation;
• when preparing objections to the Documents drawn up by the Main Customs Office, setting out your position clearly with reference to EU law (in particular, the provisions prohibiting discrimination on grounds of nationality) and demanding the annulment of the consent you signed to the appointment of representatives without your informed and voluntary (i.e. lawful) consent.

It may also be advisable to send official requests for assistance in restoring your rights and legitimate interests to the following authorities:

• The Russian Consulate General in Bonn (info‑bonn@kdmid.ru);
• The Consular Section of the Russian Embassy in Germany (infoberlin@kdmid.ru, infokonsulat@russische-botschaft.de);
• The German Embassy in Moscow (https://germania.diplo.de/ru-ru/ueber-uns/botschaft/kontakt-konsulat).

The C Cases team will continue to share useful practical information on protecting the interests of Russian citizens when their rights are violated by the customs authorities of EU countries.

If restrictive measures have been applied to you in EU countries, or you have questions about the sanctions in force in the EU, the C Cases team will gladly advise you and provide legal recommendations tailored to your situation.

Sources

• Ministry of Foreign Affairs of the Russian Federation: warning for Russian citizens planning trips to the Federal Republic of Germany (https://www.mid.ru/ru/useful_information/information/preduprezhdeniya_dlya_rossiyskikh_grazhdan/2070113/);
• Russian Consulate General in Bonn: important information for Russian citizens (https://bonn.mid.ru/ru/).