Ukrainian President Volodymyr Zelenskyy recently hinted the European Union is working on another sanctions package on Russia, less than a month after agreeing on a new raft of measures aimed at hitting the Kremlin over the full-scale invasion of its neighbor.
The first question is how quickly such a new proposal may emerge. EU diplomats whom RFE/RL spoke with under the condition of anonymity say they doubt fresh measures will be presented this side of Christmas.
Brussels has two bigger priorities at the moment: securing funding for Ukraine for the next two years (with a so-called reparations loan still the favored option) and making sure all current EU sanctions on Moscow are renewed.
Both issues need to be solved in January at the latest. The latter requires unanimity while the former needs broad political backing.
EU officials are, in other words, wary of adding another task requiring consensus and have hinted that a new sanctions package might first arrive around the fourth anniversary of Russia's full-scale invasion of Ukraine in February 2026.
This hasn't stopped EU member states from drawing up their wish-lists, though. One discussion paper seen by RFE/RL and authored by the Baltic trio Estonia, Latvia, and Lithuania as well as Germany Poland, and Sweden makes it clear the next goal should be to limit EU imports of Russian goods.
Noting that the bloc imported goods from the country to the tune of 35 billion euros last year, the six countries argue there still is plenty of leeway for the club to lessen its dependence on Moscow.
The bulk of these imports are in energy such as gas and oil as well as various agricultural products. Brussels already committed earlier this year to largely phasing out both Russian energy and agriculture imports by 2027.
Russian Steel And Phosphates
The countries are essentially looking at the next most imported Russian item: steel.
So far this year, the club has imported Russian steel to the tune of 1.3 billion euros, or 8 percent of total EU imports from the country. Most of those steel products are so-called steel slabs, a foundation material that is crafted into more elaborate steel products.
While Brussels imposed import bans on some Russian steel already back in 2022, steel slab intakes have an exemption till October 2028. This exemption could be crossed out.
Another potential target is so-called inorganic chemicals from Russia, which constitute 3 percent of total EU imports from Russia. These include anhydrous ammonia and calcium phosphates, which can be used both for agriculture but also in the plastics and pharmaceutical industries.
The discussion paper notes the United States is currently both the largest importer and exporter of these products and potential sanctions wouldn't disrupt their European supplies.
Potassium fertilizers are a similar story. While the EU has targeted nitrogen-based fertilizers with trade restrictions, imports of those that are potassium-based actually increased in 2024 compared to 2023 and 2022.
The EU still produces its own potassium fertilizers but at a higher cost, largely due to stringent environmental regulations. But the bloc could also import from other third countries such as Canada and Israel, meaning sanctions on these Russian imports wouldn't necessarily translate into a shortage for European farmers.
Targeting Russia's 'Shadow Fleet'
The EU also wants to figure out how to target Russia's "shadow fleet" -- often rickety vessels with shadowy ownership Moscow uses to circumvent the G7 oil cap. The cap has set a limit, currently at $47.60 per barrel, at which Russian crude oil is allowed to be traded.
Brussels has so far blacklisted 562 vessels trying to undercut the cap. The blacklisting means they cannot be serviced at any EU ports, but it is believed there are at least another 400 that still haven't been targeted. And they are still allowed to sail in EU waters, often causing fears of oil spills and other hazards.
France recently distributed a discussion paper among EU capitals on what more can be done in this field. The gist of Paris's proposal is that the EU and like-minded countries should focus on what it calls "a volume-driven approach."
This essentially means regulating how much oil boats are allowed to carry. While not sketching out how this would work in practice , the document, seen by RFE/RL, notes that Brussels's next move should be to hit "all enablers of the shadow fleet's, especially its financial, commercial, and logistical networks in third countries."
While this could obviously mean sanctions, the paper also suggests "introducing incentives to encourage owners of listed vessels to reintegrate legitimate trade channels" and "preventing further increase in tonnage through more stringent controls and due diligence requirements on the sales of ships."
Then there is the issue of stopping boats belonging to the shadow fleet in European waters.
Paris made headlines earlier in September when French authorities boarded the vessel Pushpa/Boracay after suspicions that the ship played a part in drone incidents in Denmark earlier that month that triggered the closure of Copenhagen airport for several hours.
France is urging the bloc to act more forcefully against boats that in fact may be stateless, arguing that "when these suspect vessels are falsely flagged, or when they have in reality already been erased of the register of the flag State they claim, they are stateless vessels" and as such make them easier for European nations to board without falling foul under the United Nations Convention on the Law of the Sea.
