Seizure of branded goods from Russians at European Union airports

Modern EU Sanctions Policy

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Late last year, there was an increase in cases of personal belongings being seized from Russian citizens departing from European Union countries (hereinafter – "EU"): laptops, phones, jewelry, cosmetics, and clothing.

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

Germany has de facto become a "territory of lawlessness" for Russian citizens. Objective and comprehensive consideration of cases concerning violations of the "sanctions regime" is not being carried out.

Inquiries from the Russian Embassy in Germany and the Russian Consulate General in Bonn regarding detentions and confiscations are being ignored.

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

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

We draw particular attention to the fact that the status of a private individual or the declared personal purpose of an item does not exempt it from sanctions restrictions: even a single item intended for personal use or as a gift is subject to prohibition if it is included in the relevant sanctions list.

The value limit applies to luxury goods (clothing, footwear, bags, jewelry, if the unit value exceeds 300 euros), consumer electronics (phones, headphones, computers, etc.), if the unit value exceeds 750 euros, musical instruments, if the unit value exceeds 1500 euros, and others.

Our Case

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One of C Cases' clients was also affected by the so-called "sanctions regime": in late 2025, the client faced the seizure of personal belongings when departing from Stuttgart airport.

Immediately before boarding the Stuttgart-Istanbul flight, the client was detained and searched by officers of the Main Customs Office in Stuttgart; 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, causing all flights to be missed), German customs officials seized items previously purchased by the Russian citizen in the UAE and drew up the following documents: a protocol of seizure of items (German: Sicherstellungsprotokoll) and a document on providing security and authorizing the person to receive correspondence (German: Sicherheitsleistung und Zustellungsvollmacht) (collectively hereinafter – "the Documents").

As it later turned out, the content of the Documents indicates that the individual is suspected of exporting luxury goods from the EU to Russia, which allegedly contradicts the requirements of one of the "sanctions" regulations in force in the EU, namely: EU Regulation 833/2014 of 31.07.2014 (hereinafter – "the Regulation"). In light of this situation, the C Cases team initiated its own investigation to protect the violated rights of the client, who was subjected to discrimination in the EU on the basis of nationality, which directly contradicts Article 21 of the EU Charter, Article 18 of the Treaty on the Functioning of the EU, and Article 3 of the German Basic Law.

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Official Position and Actions of the Main Customs Office in Stuttgart:

According to Article 3h, paragraph 2a of the Regulation, luxury goods (Luxusgüter) are defined as any goods with a value exceeding 300 euros (unless otherwise specified in Annex XVIII to the Regulation). In accordance with Article 3h, paragraph 2 of the Regulation, the following actions are prohibited concerning luxury goods for any Russian natural or legal person, or state body:

— to sell;

— to supply;

— to transfer;

— to export.

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Please note that the Regulation provides for a list of items prohibited from import into the EU and a list of items prohibited from export from the EU. Luxury goods are only included in the list of items prohibited from export from the EU.

Thus, a situation may arise where you may legally import luxury goods (generally, items valued over 300 euros) into the EU but be unable to export them (customs authorities might consider this the export of luxury goods from the EU to Russia, or, for example, transit (German: der Transit)). As a consequence, customs authorities may, at their discretion, confiscate the personal belongings of Russian citizens.

It is also important to consider that detention and inspection of a person typically occur shortly before a flight's departure, which places the detained Russian citizen in a stressful situation: the risk of missing their 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, it's usually only at the very end for signing, and a copy of the acts may not be issued). As a result, the Russian citizen departs (often buying new tickets) without their personal belongings, having signed documents under psychological pressure, the contents of which are unknown to them.

Recommendations from the C Cases team.

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To avoid such situations, the C Cases team recommends:

• carrying receipts confirming that you purchased the items outside of EU countries;
• explaining that the items were acquired and used exclusively for personal, everyday purposes, and asserting that the items have been used repeatedly, even if recently purchased;
• emphasizing the quantity and nature of the confiscated items (for example, one pair of shoes in your size, rather than 10 pairs of identical shoes, which might suggest an intent to resell them);
• highlighting the insignificance of the item's value exceeding the limit.

If customs authorities nevertheless draw up documents for the confiscation of items based on suspicion of violating the EU sanctions regime, the C Cases team recommends paying special attention to the following when signing documents:

• The document may specify a person whom you, by signing the documents, authorize to receive correspondence on your behalf regarding the case (for example, in our case, this person was the official representative of the District Court in Stuttgart (German: Amtsgericht Stuttgart);
• the document may state that you were provided with assistance in translating documents;
• the document may state that you voluntarily surrendered your belongings.

The deadline for appealing the issued acts and confiscation of belongings is 1 month from the date of their issuance. Objections should be submitted to the customs authority that directly issued them (German: einen Einspruch einlegen). If the demands contained in the objections are not met, you have the right to appeal the actions of the customs authorities in court (German: eine Klage einreichen).

When appealing the actions of customs authorities, we recommend

• send a request for information regarding your case to the person allegedly authorized to receive correspondence (in our case, to the official email of the District Court in Stuttgart (German: Amtsgericht Stuttgart): poststelle@agstuttgart.justiz.bwl.de). You may be surprised to find that the person authorized on your behalf to receive correspondence for your case no longer works for the organization, and you will have to arrange with other representatives of that organization to have correspondence sent to you;
• send a written request to the Central Customs Information Office (German: Zentrale Auskunft der Zollverwaltung) demanding clarification of the Regulation's provisions;
• when drafting objections to the documents prepared by the employees of the Main Customs Administration, you must clearly argue your position, relying on the provisions of EU regulatory acts (in particular, provisions establishing the inadmissibility of discrimination based on nationality), and demand the annulment of your signed consent to the appointment of representatives without your informed voluntary (i.e., legal) consent.

Additionally, it may be advisable to send official appeals requesting assistance in restoring violated rights and legitimate interests to the following state bodies:

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

The C Cases team will continue to provide you with useful practical information on protecting the interests of Russian citizens whose rights have been violated by customs authorities in European Union countries.

Should you encounter restrictive measures applied to you within the European Union, or if you have questions regarding sanctions currently in force in EU countries, the C Cases team will gladly provide consulting services and legal recommendations tailored to your specific situation.

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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/);
• Consulate General of Russia in Bonn: important information for Russian citizens (https://bonn.mid.ru/ru/).