Although Russian fuel imports to the EU have decreased by 80% compared to 2021, in 2024 European companies still paid Russia €22 billion for energy—more than the total amount of aid provided to Ukraine during the same period. Despite 18 rounds of sanctions, Russia continues to exploit loopholes that allow the export of natural gas and crude oil to EU member states. Some deliveries, including those to global markets, are facilitated by a “shadow fleet”, which circumvents price caps and sanction regimes.

The author of the report stresses that a full and lasting decoupling from Russian raw materials is not only possible but necessary from the perspective of both the EU’s energy security and its political sovereignty. Importantly, technical solutions such as access to LNG terminals, alternative transmission routes, and the development of renewable energy sources are already in place. The main obstacles remain political resistance, concerns over rising prices, and incomplete implementation of available mechanisms.  

“There are two main categories of loopholes that still allow Russia to earn substantial revenues from fuel exports to Europe. The first are ‘EU-designed’, such as exemptions for imports of crude oil via the Southern Druzhba pipeline. The second are ‘Russian loopholes’, meaning mechanisms for circumventing sanctions, such as re-exporting fuels via third countries (for example, India or Turkey), using the ‘shadow fleet’ to transport crude, and transferring products in EU territorial waters. Closing these loopholes is crucial to the EU’s energy security. Russia is using even minimal dependency for political leverage, and the funds obtained from European partners are helping finance the war. A rational and calculated severing of this dependency, with consideration for the technical possibilities for diversification and the cost for each member state, is essential to preserving the EU’s sovereignty and credibility,” said Maciej Zaniewicz, author of the report.

Energy Security and Reducing Dependence on Russia? Recommendations from Forum Energii and CREA for the EU

With the launch of the REPowerEU plan, the European Commission strengthened the objectives of the 2014 EU Energy Security Strategy, replacing the concept of supply diversification with the goal of full independence from Russian fuels by the end of 2027. So far, significant progress has been made in phasing out the majority of Russian oil, petroleum products, and coal.

Forum Energii and CREA have outlined a number of recommendations that can support the effective implementation of REPowerEU, while taking into account the circumstances of the most vulnerable and Russia-dependent countries.

In the case of natural gas, it is essential to introduce a complete ban on the import of natural gas, including LNG, from Russia, as well as on spot-market transactions. Alternatively, imports could be curtailed through the imposition of a 50% tariff. Additional necessary measures include a ban on the transshipment of Russian LNG within the EU, enhanced transparency in the reporting of fuel origin by EU member states, and the elimination of contracts that obscure the source of supply. At the same time, it is important to maintain a constant dialogue with Hungary and Slovakia in order to implement this plan in an effective and cost-acceptable manner.

With regard to crude oil, experts recommend lifting the derogation for the Southern Druzhba pipeline, prohibiting the conclusion of new contracts and the renewal of existing ones with Russian suppliers, enforcing bans on the import of refined petroleum products, regularly updating the list of vessels in the ‘shadow fleet’, and lowering the oil price cap to USD 30 per barrel.

In the area of LPG and fertilisers, it is recommended to impose tariffs on n-butane and  isobutane, as well as to monitor Russian and Belarussian fertilisers supply routes to prevent re-export via third countries. According to the authors, the implementation of these measures could reduce Russia’s revenues from fuel exports by as much as EUR 60 billion annually—almost three times the current value of its exports to the EU.

Europe at a Crossroads: A New Strategy for Energy Security Is Needed

Amid changing U.S. policy towards Russia and the potential easing of global sanctions, a permanent move away from Russian energy imports should become a central pillar of the EU’s new Sustainable Energy Security Strategy. Forum Energii outlines this need in its report Towards Sustainable Energy Security. Europe Needs a New Strategy Now, presenting a long-term, collective vision aimed not only at enhancing Europe’s energy resilience but also at accelerating the pace of the energy transition. 

The report is not just an analysis of current challenges but also serves as a political compass for the next two years. Disengaging from Russian fuels need not be seen as a risk, rather as an element of a well-planned, united, and effective European strategy.