SCAP and FFE call on the EU to ban exports of all key high-priority items to Kyrgyzstan.
Thursday, 30 April 2026
On 23 April 2026, the European Council adopted its 20th package of restrictive measures against Russia. The package includes restrictive measures against Kyrgyzstan. Specifically, the EU is activating its anti-circumvention tool, by prohibiting the export of computer numerical control machines and radios to Kyrgyzstan, where there is a high risk that these products will be re-exported to Russia. According to the EU Council, “this decision follows a thorough analysis of trade data showing a significant surge in re-export of common high priority items through Kyrgyzstan to Russia”.
On 23 June 2023, the EU Council created the so-called “anti-circumvention tool” – measures to target Russia’s ability to circumvent EU sanctions and export controls through third countries. According to the adopted text, “Where, following the adoption of individual measures and further engagement with the third country, it is manifest, given the volume, type or systemic nature of the ongoing circumvention, that those steps are insufficient or inadequate to prevent such circumvention in or via the third country concerned, the Union should be able to take […] exceptional, last-resort measures restricting the sale, supply, transfer or export of sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of Russia’s military, technological or industrial capacities or to the development of Russia’s defence and security sector, in a way that strengthens its ability to wage war, and whose export to Russia is prohibited under Regulation (EU) No 833/2014 to third countries whose jurisdiction is demonstrated to be at a continuing and particularly high risk of being used for circumvention.”
Activists and journalists monitoring the flow of critical goods and technology from the EU to Russia have long observed a spike in EU exports of high priority items to Kyrgyzstan. EU data shows that exports of Common High Priority items to Kyrgyzstan rose nearly 800 percent in the first 10 months of 2025 compared with pre-invasion levels, while Kyrgyz exports of the same goods to Russia increased by about 1,200 percent. The re-routing of goods via Kyrgyzstan may have raised the cost of war procurement for Russia but has enabled the flow of goods and technology that it relies on to continue to perpetrate its illegal war and war crimes in Ukraine. Despite numerous assurances by Kyrgyz authorities, Kyrgyzstan continues to undermine the effectiveness of EU sanctions against Russia.
SCAP and FFE welcome the EU’s activation of the anti-circumvention tool against Kyrgyzstan. However, we note that CNC machines and radios are not the only high priority EU exports being re-routed through Kyrgyzstan. Customs data demonstrates that other key items such as turbo-jet turbines, electronic integrated circuits, lasers and other optical instruments continue to flow into the Russian military industrial complex via Kyrgyzstan and powering the Russian war machine. Publicly available trade data demonstrates that these goods are being exported from the EU to Kyrgyzstan and then exported onwards to Russia. In the last three years, exports of these goods from Kyrgyzstan to Russia increased significantly compared to the period before the full-scale invasion. These items are indispensable components used by Russian forces to kill civilians and target civilian infrastructure in Ukraine. As long as the Kyrgyzstan route is open to these items, Russia will continue to terrorise Ukrainian civilians and occupy Ukrainian land.
We call on the EU Council to swiftly expand its list of banned exports to Kyrgyzstan to cover all high priority goods and items for which there is no historically proven domestic market. The EU must act strongly and decisively. Its previous strategy of ramping up sanctions in incremental steps has proven ineffective, as it gives Russia and its proxies time to adopt and thrive. Evidence has shown that only major and far-reaching measures have tangible effects on Russia’s war economy and battlefield capability.