LPG in the 12th Sanctions Package
19 December 2023
On 18 December the so-called 12th package of sanctions against Russia over its continuing invasion of Ukraine was published in the Official Journal of the European Union. As expected, it also covers liquefied gas (LPG).

Council Regulation (EU) No 2023/2878 of 18 December 2023 concerns many categories of products, among them liquefied gas (LPG), imported into Poland under the following customs codes:
- CN 2711 12 - liquefied propane,
- CN 2711 13 - liquefied butanes other than n-butane and isobutane of purity >95%,
- CN 2711 14 - liquefied ethylene, propylene, butylene and butadiene,
- CN 2711 19 - gaseous hydrocarbons, liquefied, not elsewhere classified.
On the basis of judgment No. C-286/15 of the Court of Justice of the European Union of 26 June 2016 on the classification of gas mixtures, CN code 2711 19 also covers propane-butane mixes, which in the first half of 2023 accounted for about two-thirds of the volume of LPG imports from the Russian Federation.
In total, Regulation No 2023/2878 placed restrictive measures on customs codes accounting for 90% of LPG brought into Poland from Russia. The new sanctions take effect on 19 December this year, but with a transition period that allows liquefied gas to be imported from Russia until 20 December 2024 under acquired rights, that is under contracts concluded before the sanctions entered into force.
The agreed transition period matches the position expressed publicly in 2023 by the Polish Ministry of Climate and Environment and consulted with businesses.
According to data for the first 10 months of 2023, the share of liquefied gas supplies from Russia in total Polish imports fell to around 48%. The second-largest supplier to the Polish market remains Sweden (21.2%), and the third is Norway (5.2%). Next come the Netherlands (4.3%) and the United Kingdom (4.2%).

More data on the structure of Polish LPG imports can be found in the article The LPG Market in the First Half of 2023 and in the POGP Annual Report.




