Since March 10, 2023, Türkiye has stopped the transit of some goods to Russia via Türkiye without an official explanation and despite the fact that no sanctions against Russia have been formally imposed. The information we obtained indicates that the Turkish customs officials and representatives of the Ministry of Trade justified the halt by explaining that there is a technical problem in the e-customs system. Furthermore, within this context, Turkish customs officials added that they expect that the problem would be resolved soon.

Currently, there is no reliable information regarding which products this de facto block applies to due to a lack of an official explanation or a legal directive. Yet, it appears that the halt only applies to the transit through Türkiye of EU-sanctioned goods. That said, due to the paucity of information at this point, it is very difficult to assess the reasoning behind or confirm the scope of the halt. Thus, there is a possibility that the halt encapsulates more than just the sanctioned goods. Similarly, there is no estimation of when the block will be lifted. Nonetheless, according to the available information, the halt does not seem to affect the exportation of goods from Türkiye to Russia and importation from Russia to Türkiye – in other words, the impact is on EU-sanctioned goods transiting via Türkiye.

Despite the de facto situation, there is no regulatory change regarding Türkiye’s approach to sanctions against Russia. Türkiye adopts sanctions through either passing laws or implementing presidential decrees, and Türkiye is not obligated to transpose EU or US sanctions into local law. Since the beginning of the war, Türkiye has not passed any laws or adopted any presidential decrees with the aim of imposing sanctions against Russia.