EU General Court upholds EU sanctions on Russian Maritime Register of Shipping & annuls withdrawal of recognition as an EU-certified ship inspector as disproportionate

10 November 2026

In 2022, the EU sanctioned the ‘Russian Maritime Register of Shipping (RMRS)’ under Regulation (EU) 833/2014 and Decision 2014/512.  RMRS is a Russian state non-profit organisation that inspects and certifies ships; it was registered as an EU-recognised organisation for this purpose under Regulation (EC) 391/2009 on common rules and standards for ship inspection and survey organisations at the time it was sanctioned.

The EU sanctions measures on RMRS imposed by Reg 833/ Decision 2014/512 are summarised on the EU-Russia section of this site and consist of:

• an investment ban (Article 1(4)(a));

• a transaction ban (Article 1aa(1)(a));

• a ban on ships certified by RMRS from accessing EU ports and locks (Article 4ha(1a));

• ‘withdrawal of recognition’, ie the EU Council removed RMRS from the list of EU-recognised ship inspectors registered under Reg 391/2009 (Article 1ab(3)).

RMRS applied to the EU General Court to annul the Decision imposing those measures; its application to annul the Reg 833 measures was inadmissible as out of time. RMRS said the EU Council had failed to state reasons, breached the principle of proportionality, breached RMRS’ rights of defence by failing to notify it before adopting the measures, and had no power to withdraw its recognition under Article 1ab(3) because under Reg 391 that decision is for the EU Commission not the Council.

In its judgment last week in RMRS v Council, Case T-535/24 (press release) the Court:

• dismissed the application to annul the port and lock ban (Article 4ha(1a)) as inadmissible because RMRS was not ‘directly concerned’ under Article 263 TFEU because the ban applies to ships certified by RMRS and only indirectly affects RMRS’ legal position.

• dismissed the application to annul the investment ban (Article 1(4)(a)) and transaction ban (Article 1aa(1)(a)) because:
  • the Council had given sufficient reasons for these measures (increasing the costs of Russia’s actions to pressurise it to end the war in Ukraine).
  • the measures were not disproportionate, since targeting a Russian state-owned entity could help pressure Russia to end the war and RMRS had failed to show that there was an equally effective, less onerous, alternative to these measures.
  • RMRS had failed to show that it was prejudiced by the failure to notify, so the failure did not justify annulment.

• On the withdrawal of recognition (Article 1ab(3)), the Court:
  • dismissed RMRS’ argument that the Council had failed to state reasons, holding that the withdrawal followed from the transaction ban imposed on RMRS as an entity wholly owned by the Russian state.
  • held that the Council had power to withdraw RMRS’ recognition under its common foreign and security policy powers (Article 29 TEU). The withdrawal pursued a different objective (pressurising Russia to end the war) from Regulation 391 (maritime safety), so the Council did not have to follow the Commission’s procedure under that Regulation.
  • held that the withdrawal of recognition was disproportionate insofar as it affected RMRS. Temporarily pausing RMRS’ status on the Reg 391 list of approved inspectors until sanctions are lifted (ie suspending recognition) would have been equally effective in pursuing the EU’s objective, but less onerous for RMRS. The Court rejected the Council’s and Commission’s argument that suspension could create maritime safety risks, and so was not a feasible alternative to withdrawal.

Therefore, the Court annulled Article 1ab(3) insofar as it concerns RMRS, but maintained its effects for 2 months and 10 days, to uphold legal certainty because the corresponding sanctions measure in Reg 833 (Article 5ae(4)) remains in force.

RMRS’ application challenged the measures as renewed until 31 July 2026 under Decision (CFSP) 2025/2648. In June 2026, the Council renewed the measures again, including Article 1ab(3) on the withdrawal of recognition, until 31 July 2027 under Decision (CFSP) 2026/1437. RMRS lodged another application against the Council (T-674/26) on 7 October 2026.