EU Warns of High Risk of Plywood Sanctions Evasion

On Friday, the European Commission issued an alert warning of a high risk of sanctions circumvention in plywood imports.

Plywood, particularly birch plywood, is a significant revenue source for Russia and Belarus, the Commission stated. EU sanctions prohibit the purchase, import, or transfer—directly or indirectly—of plywood and other wood products originating in or exported from Russia or Belarus. Related services, including brokering, logistics support, and warehousing, are also banned.

To bypass these restrictions, Russian and Belarusian producers use third-country companies to repackage and relabel their products, the Commission warned. These companies attempt to conceal the true origin of the goods by providing false or misleading documents, such as invoices, certificates of origin, proof of harvest location, and independent third-party certifications, e.g., green label.

The alert identified the following red flags:

• Plywood made of birch
• Producer/exporter in China, Kazakhstan, Türkiye, or another country with trade links to Russia or Belarus and/or sudden, recent growth in plywood exports to the EU
• Processing operations that are not economically justified
• Illogical logistic routes

EU operators (individuals and entities) are legally liable whether they violate sanctions intentionally or by negligence, the Commission explained. They cannot escape liability if they fail to perform due diligence. Beyond reputational damage, EU operators that violate sanctions risk administrative and criminal penalties. Voluntary self-disclosure can be a mitigating factor. The EU can also impose sanctions against companies in the supply chain.

In parallel, illicit imports of plywood are investigated for customs fraud. Russian birch plywood has been subject to anti-dumping duties at import to the EU since 2021; following an investigation, these measures were extended to Kazakhstan and Türkiye in 2024. Payment of tariffs does not exempt companies from liability under sanctions law, the Commission said.