Tiit Riisalo 16.05.2023 nr 10.1-13/451-1
Majandus- ja infotehnoloogiaminister
Majandus- ja Kommunikatsiooniministeerium
Austatud minister
Edastame Teile Euroopa Komisjoni volinike Adina Văleani ja Mairead McGuinnessi kirja 15.
maist 2023 nr ARES(2023)4735137 / 3395704.
Lugupidamisega
Aivo Orav
alaline esindaja
Lisa: kiri 2 lk
Raili Lillemets
+32 2227 4375
[email protected]
Rue Guimard 11/13 1040 Brüssel Tel: +32 2 227 39 10
[email protected] https://eu.mfa.ee/et/
Ref. Ares(2023)3395704 - 15/05/2023
EUROPEAN COMMISSION
Adina Vălean Mairead McGuinness
Member of the Commission Commissioner of the European Commission
Transport Financial services, financial stability and
Capital Markets Union
Brussels, 15.05.2023
Ares(2023)4735137
Dear Ministers,
Thank you for your letter calling for additional measures in respect of land and maritime
transport to put further pressure on Russia and Belarus in view of Russia’s military aggression
in Ukraine. We apologise for the delay in replying which was due to an administrative error.
As it has been more than one year since the Russian aggression against Ukraine, several
measures have already been taken which address your call for action in the road and maritime
sector.
On 8 April 2022, the Council prohibited road transport undertakings, established in Russia or
Belarus, from transporting goods in the Union, including in transit.1 At the same time, the
Council prohibited access to ports by vessels registered under the flag of Russia.2 The
implementation of these restrictive measures is the responsibility of Member States within
their respective jurisdictions.
1
Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning
restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (OJ L 111, 8.4.2022,
p. 1) ; Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006
concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the
Russian aggression against Ukraine (OJ L 111, 8.4.2022, p. 67).
2
Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning
restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (OJ L 111, 8.4.2022,
p. 1).
Arkadiusz Pluciński
Deputy Permanent Representative of Poland to the EU
Rue Stevin 139,
1000 Brussels
Belgium
[email protected]
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111
The European Commission took note of the decisions of the Transport Management Board of
the International Transport Forum (ITF) of 4 May 2022 to restrict the participation of Russia
and Belarus in the ITF significantly in response to the invasion of Ukraine.3 The measures in
particular envisage that the Russian Federation and Belarus will not be included in ITF
research projects and the Bureau of the Transport Research Committee that oversees them.
As to your proposal to revoke the recognition by the EU member states of the permits of the
European Conference of Ministers of Transport (ECMT) for road transport carried out by
hauliers established in Russia and Belarus, the road transport sanctions adopted by the
Council on 8 April 2022 prohibit such recognition.
Regarding your proposal to suspend the application of the Convention on International
Transport of Goods Under Cover of TIR Carnets (TIR Convention) to transport operations
with Russia and Belarus. The prohibition on road transport undertakings established in Russia
or Belarus from transporting goods by road in the Union, already includes customs transit
procedures and thus transport under the TIR Convention. For goods not covered by restrictive
measures, the TIR procedure can still be used by operators from other countries than Russia
or Belarus.
While the TIR Convention envisages the denunciation of a contracting party in its Article 54,
it has no provisions on suspension of the Convention. The Union could unilaterally decide not
to apply the Convention to Russia or Belarus but could face criticism for not abiding by
international agreements. Furthermore, goods for which the transport is allowed can be
transported without a customs transit procedure.
The Commission remains determined to ensure a unanimous and strong response from the EU
to Russian aggression against Ukraine.
Yours sincerely,
Adina Vălean Mairead McGuinness
3
ITF communiqué on the decision taken by members of the ITF’s Transport Management Board
(Extraordinary Session 4/05/2022): https://www.itf-oecd.org/member-countries-vote-restrict-
participation-russia-and-belarus-operational-activities-itf-0.
Electronically signed on 15/05/2023 15:23 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121