EU General Court Partially Annuls Sanctions on Russian Maritime Register

The EU General Court on 4 November partially annulled the Council's withdrawal of European recognition from the Russian Maritime Register, ruling the measure disproportionate — while keeping its effects alive for up to two months and ten days. The judgment in Case T-535/24 does not reopen European ports, does not lift financial restrictions, and does not end the prohibition on transactions with the organization.

What did the General Court decide?

The Court annulled only one provision: Article 1ab(3) of Decision 2014/512/CFSP, in its contested version and extensions, insofar as it withdraws the recognition granted to RMRS under Regulation 391/2009. The judges found the definitive withdrawal went beyond what the sanctions required.

Their reasoning turned on proportionality. A suspension of recognition, the Court held, could have prevented RMRS from performing tasks reserved for EU-recognized organizations, achieving the Council's objective through a less onerous measure. Withdrawal, by contrast, produces consequences that may continue after the sanctions end: to regain recognition, RMRS would need a new procedure initiated by a Member State, a process it cannot start itself and one with no guarantee of a favorable outcome.

The Court did not question the Council's competence to act through sanctions. RMRS had argued that withdrawal of recognition belonged solely to the European Commission under maritime-safety rules. The General Court rejected that argument, holding that the Commission's safety powers and the Council's foreign-policy powers pursue different objectives and may complement each other.

Why can't RMRS resume activities immediately?

Two limitations block any immediate resumption:

• The effects of the annulled provision are maintained for no more than two months and ten days from delivery of the judgment, to avoid legal uncertainty.
• Article 5aa(4) of Regulation 833/2014, which provides for the same withdrawal of recognition, was not annulled. The application against the regulation's provisions was dismissed as inadmissible because it was lodged after the time limit for bringing an action expired.

The annulment therefore does not extend to all maritime measures against RMRS, nor does it automatically restore national authorizations.

What survives the ruling?

The financial restrictions and the prohibition on transactions with RMRS remain fully in force. The General Court rejected the organization's criticisms that these measures were disproportionate, finding they could contribute to the pressure exerted on Russia. The economic losses invoked by RMRS were insufficient to demonstrate their unlawfulness.

The challenge to the prohibition on access to EU ports and locks for vessels certified by RMRS was dismissed on a separate procedural ground, without examination of its substance. The Court held that RMRS was not directly concerned within the meaning of the conditions for an annulment action, because the prohibition alters the legal situation of vessel owners and operators — and economic consequences for the certifying body do not, by themselves, establish direct legal concern.

That outcome leaves the port-access prohibition in force untouched. The judgment does not reopen European ports to the vessels concerned and must not be read as a general removal of sanctions against the Russian register.

What is at stake for practitioners?

The case matters for anyone advising shipowners, operators, or classification clients touched by the EU's Russia sanctions architecture. It confirms that proportionality review can bite even on foreign-policy sanctions, and that a provisional measure cannot impose consequences outlasting the sanctions regime itself. But the practical impact today is nil: recognition remains withdrawn under the regulation, transactions remain prohibited, and ports remain closed to affected vessels. The deadline structure also demands attention. An appeal to the Court of Justice lies solely on points of law, within two months and ten days of notification — a period the Court stressed is distinct from the two months and ten days during which the annulled provision's effects are maintained, which runs from delivery of the judgment.

Who is RMRS?

The Russian Maritime Register is a nonprofit organization headquartered in Saint Petersburg and wholly owned by the Russian state. It classifies, inspects, and certifies vessels flying Russian and foreign flags. Its recognition in the Union since 1998 allowed it to perform certain inspection and certification tasks for vessels of the Member States. The Council introduced the restrictions in the context of Russia's war of aggression against Ukraine, aiming to increase pressure on the Russian state through limits on funding access, transaction prohibitions, and maritime restrictions.