First Partial EU Sanctions Relief for Windows Manufacturers in Four Years

While the 20^th EU sanctions package expands the list of sanctioned goods, there is also a limited exemption from sanctions for European windows manufacturers subject to individual approval by competent regulatory authorities.

The Russian-German Chamber of Commerce has contributed to this result by communicating with the German Government and outlining the pressures affecting German windows manufacturers.

In July 2025, the EU’s 18^th sanctions package prohibited the supply of a wide range of windows and doors components to Russia, including metal mountings, fittings and similar articles suitable for furniture, doors, windows, base metal hat-racks, hat-pegs, brackets, and similar fixtures, as such goods could contribute to the enhancement of Russian industrial capacities. Given the strong presence of German windows manufacturers in the Russian market, these restrictions had a particularly significant impact on the sector.

In the 20^th sanctions package the EU introduced the possibility to obtain individual approvals for narrow CN codes positions of goods (plates, sheets, film and strips of vinyl chloride polymers containing at least 6% by weight of plasticizers, with a thickness not exceeding 1 mm (3920 43 10 99), fastening hardware and fittings of base metals used for windows and balcony windows (8302 41 50)), which can be strictly necessary for the sale of windows. In Germany, such approvals are issued by the Federal Office for Economic Affairs and Export Control (BAFA).

This case demonstrates that a reasonable dialogue and efforts are possible.