Civil society appeal to EU and G7: Plug energy sanctions loopholes and strengthen enforcement to end the war
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21 February 2024

Open letter to:

Justin Trudeau, Prime Minister of Canada

Emmanuel Macron, President of the Republic of France

Olaf Scholz, Chancellor of the Federal Republic of Germany

Giorgia Meloni, Prime Minister of Italy

Fumio Kishida, Prime Minister of Japan

Rishi Sunak, Prime Minister of the United Kingdom

Joe Biden, President of the United States of America

Ursula von der Leyen, President of the European Commission

Charles Michel, President of the European Council

Roberta Metsola, President of the European Parliament

Civil society appeal to EU and G7: Plug energy sanctions loopholes and strengthen enforcement to end the war

Dear G7 and European Union leaders,

The European Union and G7 should tighten their grip on Russia’s key revenue streams from exports of fossil fuels, ban Russian LNG gas imports and close all loopholes in existing sanctions. It is good that Europe supports Ukraine financially and militarily. But it is just as important to fully end the financing of the Russian war machine through fossil fuel imports, which is still a reality, say more than 300 European, international and Ukrainian NGOs in a public appeal to leaders.

Sanctioning countries have significantly reduced their reliance on Russian fossil fuels, but more must be done to stop purchasing fuels that finance the Kremlin’s war chest. Through measures such as the EU oil import ban and G7 price cap, Russia’s export earnings from oil have been cut by 14%, costing them EUR 34 billion. However, the oil price cap’s impact is far short of what could have been achieved with greater monitoring and enforcement of the policy, paired with a lower price level. Two years on, the EU and G7 have purchased EUR 202 bln of fossil fuels from Russia since Putin’s full-scale invasion of Ukraine.

Russia’s war as an onslaught on international rules-based order, democracy and human rights. We welcome the recent decision by the European Council to support Ukraine with EUR 50 billion in aid. However, the EU’s recent aid commitment represents 27% of their total fossil fuel imports purchased from Russia since the beginning of their full-scale invasion, estimated at over EUR 185 billion. More needs to be done to support our allies and wean the EU off of the Russian fossil fuel exports that fund the war, including a complete phase-out of Russian pipeline gas.

The EU has introduced 12 consecutive sanctions packages on the Russian economy, designed to deprive the aggressor of access to finance, insurance, advanced technologies, and engineering services and to limit its export earnings. The EU and G7 have also adopted a globally applicable price cap on Russian oil in December 2022. Yet, insufficient enforcement and the lack of comprehensive sanctions against Russia’s fossil fuel exports are downgrading the efficiency of the sanctions regime and undermining the overall efforts to deprive Russia of economic means for waging war.

Russia’s 2024 federal budget increases to the military-industrial complex doubled compared to 2022, unprecedented military spending since Soviet times. The major shift sends a third of all governmental funding to the army, threatening regional stability and the future of democracy and security in Europe. Meanwhile, Russia expects to replenish its budget with 11.5 trillion rubles (USD 127 billion) from oil and gas sector revenues. Russia can spend so lavishly on its military mainly because of its oil and gas revenues.

The EU and G7 countries contribute to this expanding war chest by inadequately enforcing sanctions against Russian oil and gas and leaving loopholes wide open that Russia exploits daily.

In solidarity with the Ukrainian people, the demand the G7 and EU take the following actions:

  1. Fully enforce and lower price caps on Russian crude oil and oil products and introduce transparent and verifiable compliance mechanisms for oil traders and shippers, especially those who operate European-owned and P&I (Protection & Indemnity) insured tankers that export Russian oil. The price cap on Russian crude oil should be set much closer to its production cost (averaging USD 15 per barrel), at USD 30 per barrel, which would have slashed Russia’s revenue by EUR 37 bn (25%).

  2. Prevent Russia from further expanding the shadow fleet of dangerous, practically uninsured and unaccountable old tankers, operating through illegal and dubious management arrangements and lacking transparency in ownership. This is necessary not only to reduce Russia’s ability to finance the war of aggression with oil money but also to prevent looming environmental catastrophes from possible major oil spills. The EU and G7 should introduce a spill insurance verification programme for vessels that travel through their waters. This could exclude ‘shadow’ tankers without spill insurance from travelling through their most travelled route from Baltic ports whilst reducing the risk of environmental catastrophe. If this policy banned many ‘shadow’ tankers from transporting oil from the Baltic and Black Sea ports, it could increase Russia’s reliance on legally insured vessels and enhance the leverage of the oil price cap policy.

  3. Close the “refining loophole”, which allows EU and G7 countries to import oil products — mainly diesel, jet fuel and gasoline — produced from Russian oil at refineries in third countries like India, Turkey or UAE. The “refining loophole” legally allows Russian oil to be processed and flow into the EU and G7 countries, preserving Russian export volumes and earnings.

  4. Fully ban liquefied natural gas (LNG) imports from Russia and its transhipment in European ports for exports to other countries. In 2022-2023, the exports of Russian LNG to global markets were expanding, while the opposite is required to cut the Kremlin’s budgetary income that funds the war of aggression and avoid the severe climate impacts of uncontrolled and unaccounted methane emissions in the Russian LNG supply chain. The EU should keep true to the commitments under the REpowerEU plan and also fully ban Russian pipeline gas imports.

  5. Take decisive actions to reduce oil and gas consumption and end import dependency to deflate the Russian war economy. Such actions include requiring company car fleets in Europe to shift to all-electric vehicles, which would help minimise petroleum demand and oil prices. Further efforts can consist of banning the installation of gas-fired boilers in new or retrofitted buildings, facilitating the accelerated market roll-out of heat pumps, prohibiting the production of single-use plastics, adopting and implementing ambitious energy efficiency improvement plans and streamlining permitting and providing governmental support for the construction of renewable energy projects. Follow-up on implementation of widely announced decarbonisation commitments is also essential.

We underscore that tightening sanctions against Russian oil and gas exports isn’t just about ending a war - it’s about dismantling the foundation that enables autocracy to thrive. It’s a global imperative to foster energy independence, peace, climate action and democratic resilience. We also must swiftly welcome Ukraine into the European Union.


  1. Transport & Environment Belgium, EU

  2. NGO Center for Environmental Initiatives “Ecoaction” Ukraine

  3. Razom We Stand Ukraine

  4. Centre for Research on Energy and Clean Air (CREA) United Kingdom

  5. Deutsche Umwelthilfe Germany

  6. Leave it in the Ground Initiative (LINGO) Belgium

  7. Green Transition Denmark Denmark

  8. Bond Beter Leefmilieu Belgium

  9. Ukrainian Security and Cooperation Center Ukraine

  10. Danube-Carpathian Programme Ukraine, Ukraine

  11. Climate Action for Lifelong Learners (CALL) Canada

  12. For a Better Bayou USA

  13. 2Celsius Romania

  14. VšĮ Žiedinė ekonomika Lithuania

  15. EKOenergy ecolabel Finland

  16. Net Impact The Gambia Gambia

  17. Oil and Gas Action Network USA

  18. Wall of Women USA

  19. Institute of legislative ideas Ukraine

  20. Egyptian Green Party Egypt

  21. Earth Action, Inc. USA

  22. Disability Peoples Forum Uganda Uganda

  23. International Partnership for Human Rights Belgium

  24. Public Eye Switzerland

  25. Clean Air Action Group Hungary

  26. Expert Forum (EFOR) Romania

  27. ICO “Environment - People - Law” Ukraine

  28. NGO “Technology of Progress” Ukraine

  29. NGO “Open Data Association” Ukraine

  30. Milieudefensie | Friends of the Earth NL Netherlands

  31. NGO Ecoclub Rivne Ukraine

  32. Transform Scotland Scotland

  33. Uplift United Kingdom

  34. NGO Sustainable Development Agency SYNERGY Ukraine

  35. NGO Social Initiative “City of the Sun” Ukraine

  36. Black Sea Women’s Club Ukraine

  37. NGO Environmental Club Eremurus Ukraine

  38. Anti-corruption Headquarters Ukraine

  39. NGO Ekoltava Ukraine

  40. Institute for Social and Economic Transformation Ukraine

  41. Planet Botanical Garden Ukraine

  42. Plato NGO Ukraine

  43. Ukrainian Nature Conservation Group Ukraine

  44. Anti-Corruption Research and Education Centre Ukraine

  45. Andy Gheorghiu Consulting Germany

  46. Clean Cities Campaign Poland Poland

  47. Nordic Ukraine Forum Sweden

  48. EUROPEUM Institute for European Policy Czech Republic

  49. Formando Rutas Germany

  50. FPPE Poland

  51. Center for the Study of Democracy Bulgaria

  52. Association “Energy Efficient Cities of Ukraine” Ukraine

  53. Naturschutzbund Deutschland (NABU) e.V. Germany

  54. Rainforest Action Network USA

  55. Uppsala University Sweden

  56. Institute for Economic Research and Policy Consulting Ukraine

  57. Eco Bucha Ukraine

  58. Deutsche Umwelthilfe e.V. Germany

  59. CEE Bankwatch Network Romania

  60. Instytut Spraw Obywatelskich Poland

  61. Center for international cooperation and project implementation Ukraine

  62. France

  63. Kyiv Municipal League of Public Organizations of People with Disabilities Ukraine

  64. National Ecological Center of Ukraine Ukraine

  65. Center for International Environmental Law France

  66. Ecosense, NGO Ukraine

  67. U-Cycle ( NGO Kyiv Cyclists’ Association) Ukraine

  68. Earth Action, Inc. USA

  69. Aid Organization Bangladesh

  70. Net Impact The Gambia Gambia

  71. Agency for sustainable development of the Carpathian region “FORZA” Ukraine

  72. Women Engage for a Common Future - WECF Netherlands

  73. Africa Bureau For Climate stories-ABOS Kenya


  75. Asociación Con Ucrania Spain

  76. Climate Action Campaign, Humboldt Unitarian Universalist Fellowship USA

  77. Adarsha Samajik Progoti Sangstha Bangladesh

  78. Green 13 Canada

  79. Associazione Cristiana degli Ucraini in Italia Italy

  80. Rozviy, Youth Climate Initiative Ukraine

  81. Minerva Ventures USA

  82. NGO “Green World” Ukraine

  83. UWEC Work Group Georgia

  84. Gower Street United Kingdom

  85. GDU Project Helmholtz Center Berlin Germany

  86. VCS Verkehrs-Club der Schweiz Switzerland

  87. NGO Plato Ukraine

  88. Chaloupky o.p.s. Czech Republic

  89. Just Finance International Europe

  90. Promote Ukraine Belgium

  91. Bellona Europa Belgium

  92. Estonian Green Movement Estonia

  93. Social Justice Committee, St. Andrew’s United Church of Canada, Halifax Canada

  94. Grandmothers Act to Save the Planet (GASP) Canada

  95. The Secretariat of the Steering Committee of the Eastern Partnership Civil Society Forum Belgium

  96. 198 methods USA

  97. Global Witness United Kingdom

  98. Atlantic Energy United Kingdom

  99. Zero Waste Society Ireland

  100. Canopea Belgium

  101. Limity jsme my Czech republic

  102. Earthsight United Kingdom

  103. Businesses for a Livable Climate USA

  104. Call to Action Colorado USA

  105. CatholicNetwork US USA

  106. Colorado Businesses for a Livable Climate USA

  107. Community for Sustainable Energy USA

  108. Greater New Orleans Housing Alliance USA

  109. Green House Connection Center USA

  110. Indivisible Ambassadors USA

  111. Interstate 70 Citizens Advisory Group USA

  112. Larimer Alliance for Health, Safety, & Environment USA

  113. Littleton Business Alliance USA

  114. Mayfair Park Neighborhood Association USA

  115. Mental Health & Inclusion Ministries USA

  116. Mind’s Eye Productions USA

  117. Montbello Neighborhood Improvement Association USA

  118. North Range Concerned Citizens USA

  119. Our Sacred Earth USA

  120. RapidShift Network USA

  121. Save the Environmental Protection Agency USA

  122. Small Business Alliance USA

  123. Southwest Organization for Sustainability USA

  124. Spirit of the Sun USA

  125. System Change Not Climate Change USA

  126. Texas Campaign for the Environment USA

  127. Unite North Metro Denver USA

  128. Wall of Women USA

  129. Western Slope Businesses for a Livable Climate USA

  130. Womxn from the Mountain USA

  131. Working for Racial Equity USA

  132. Climate Risk Horizons India

  133. ZERO – Association for the Earth System Sustainability Portugal

  134. Association of Ethical Shareholders Germany

  135. Ukrainian Network of Integrity and Compliance (UNIC) Ukraine

  136. NGO “Unique Planet” Ukraine

  137. NGO Green Liberty Ukraine

  138. NGO SaveDnipro Ukraine

  139. NGO “Office for the Environment” Ukraine

  140. NGO “Green Generation” Ukraine

  141. Economic Expert Platform Ukraine

  142. Civil Network OPORA Ukraine

  143. WWF-Ukraine Ukraine

  144. Centre for Liberal Modernity (LibMod) Germany

  145. Greenpeace CEE Ukraine

  146. Vitsche e.V. Germany

149-238. Business for Ukraine Coalition, on behalf of 89 international and Ukrainian members.

239-249. Energy Transition Coalition, uniting 10 Ukrainian organizations.

250-300+. RISE Ukraine Coalition, uniting more than 50 organizations.

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