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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

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

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. 350.org 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
  74. TRAFFED-RDC AMIS D’AROCHA DRC
  75. Asociación Con Ucrania Spain
  76. Climate Action Campaign, Humboldt Unitarian Universalist Fellowship USA

Adarsha Samajik Progoti Sangstha Bangladesh

Green 13 Canada

Associazione Cristiana degli Ucraini in Italia Italy

Rozviy, Youth Climate Initiative Ukraine

Minerva Ventures USA

NGO "Green World" Ukraine

UWEC Work Group Georgia

Gower Street United Kingdom

GDU Project Helmholtz Center Berlin Germany

VCS Verkehrs-Club der Schweiz Switzerland

NGO Plato Ukraine

Chaloupky o.p.s. Czech Republic

Just Finance International Europe

Promote Ukraine Belgium

Bellona Europa Belgium

Estonian Green Movement Estonia

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

Grandmothers Act to Save the Planet (GASP) Canada

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

198 methods USA

Global Witness United Kingdom

Atlantic Energy United Kingdom

Zero Waste Society Ireland

  1. Canopea Belgium
  2. Limity jsme my Czech republic
  3. Earthsight United Kingdom
  4. Businesses for a Livable Climate USA
  5. Call to Action Colorado USA
  6. CatholicNetwork US USA
  7. Colorado Businesses for a Livable Climate USA
  8. Community for Sustainable Energy USA
  9. Greater New Orleans Housing Alliance USA
  10. Green House Connection Center USA
  11. Indivisible Ambassadors USA
  12. Interstate 70 Citizens Advisory Group USA
  13. Larimer Alliance for Health, Safety, & Environment USA
  14. Littleton Business Alliance USA
  15. Mayfair Park Neighborhood Association USA
  16. Mental Health & Inclusion Ministries USA
  17. Mind’s Eye Productions USA
  18. Montbello Neighborhood Improvement Association USA
  19. North Range Concerned Citizens USA
  20. Our Sacred Earth USA
  21. RapidShift Network USA
  22. Save the Environmental Protection Agency USA
  23. Small Business Alliance USA
  24. Southwest Organization for Sustainability USA
  25. Spirit of the Sun USA
  26. System Change Not Climate Change USA
  27. Texas Campaign for the Environment USA
  28. Unite North Metro Denver USA
  29. Wall of Women USA
  30. Western Slope Businesses for a Livable Climate USA
  31. Womxn from the Mountain USA
  32. Working for Racial Equity USA
  33. Climate Risk Horizons India
  34. ZERO – Association for the Earth System Sustainability Portugal
  35. Association of Ethical Shareholders Germany
  36. Ukrainian Network of Integrity and Compliance (UNIC) Ukraine
  37. NGO “Unique Planet” Ukraine
  38. NGO Green Liberty Ukraine
  39. NGO SaveDnipro Ukraine
  40. NGO “Office for the Environment” Ukraine
  41. NGO “Green Generation” Ukraine
  42. Economic Expert Platform Ukraine
  43. Civil Network OPORA Ukraine
  44. WWF-Ukraine Ukraine
  45. Centre for Liberal Modernity (LibMod) Germany
  46. Greenpeace CEE Ukraine
  47. 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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