In the alert, the Commission flags that to bypass these restrictions, Russian and Belarusian producers frequently use third-country companies to disguise the origin of their plywood. These schemes involve falsified or misleading documents such as invoices, certificates of origin and proof of harvest locations. Goods are often relabelled, repackaged and transported through deceptive routes by road, rail, or sea.

The alert reiterates that enhanced due diligence is critical for EU market participants, including importers, intermediaries, and end-users. Key steps include verifying the true origin of plywood and looking out for red flags such as birch plywood linked to regions with trade ties to Russia or Belarus, economically unjustifiable processing operations, or suspicious logistical routes.

EU operators bear legal responsibility for breaching sanctions, whether by intent or negligence. Failing to conduct due diligence can result in reputational harm, financial penalties, and even criminal charges. Voluntary self-disclosure may act as a mitigating factor, but offenders remain exposed to investigations and sanctions enforcement.

Operators should stay informed through resources such as the European Commission’s notices and expert guidance. Comprehensive due diligence not only protects against sanctions violations but also positions businesses as responsible participants in the EU market.

European Commission’s alert can be found here.