The European Union has published a factsheet on Incoterms®, in particular on the ‘Ex Works’ (EXW) rule. It explains how the Incoterms® rules relate to EU sanctions and what responsibilities sellers and buyers have in EXW deliveries.
EU legislation on restrictive measures (sanctions) is laid down in Council Regulations. Compliance with these sanctions is mandatory for all persons subject to EU jurisdiction.
This includes individuals within the EU, EU citizens regardless of their place of residence, companies established in the EU regardless of whether they do business within or outside the EU, and foreign companies doing business in the EU.
Private law agreements cannot deviate from EU sanctions. The use of Incoterms® rules such as EXW therefore does not alter the sanctions-related obligations in any way. This includes the obligation to ensure that certain goods do not end up in prohibited destinations such as Russia or Belarus. Exporters/sellers should take all necessary measures to this end.
Links:
Incoterms „Ex Works“ rule (EXW)
Source: