Will the Russian Gas Loophole Finally Close?

An Analysis of New European Union Sanctions and Policy on Russian Gas Imports

The now completed TurkStream pipeline in Bulgaria.
(Image Source: iStock; https://tinyurl.com/y5jenytx)

By Lucas Vroege

In February 2022, Russia’s invasion of Ukraine shattered Europe’s complacent energy policy. In response, the European Union (EU) launched the RePowerEU initiative in April 2022, with the intent of limiting Russia’s economic leverage on the EU.[i] In February 2022, 45% of EU natural gas imports came from Russia; currently, Russian gas imports have fallen to only 13% of the EU’s imports.[ii] Despite the impressive decline, EU nations’ economic dependence on Russian natural gas remains a strategic liability. While the commitment of EU leadership is clear, the EU remains a major importer of piped natural gas. The European Union has responded decisively to this challenge by adopting its 19th round of sanctions, which includes a complete Russian LNG import ban.[iii] Furthermore, on October 20th, the European Council proposed an updated version of the REPowerEU, which calls for an end to pipeline natural gas imports from the Turkstream pipeline by 2028.[iv] These two measures represent significant steps toward degrading the finances of the Russian war machine, which has caused 14,383 Ukrainian civilian deaths.[v]

The need for further action by the EU is driven by the impact of EU gas consumption on the Russian military machine. While the EU has limited its economic exposure to Russia, it remains a significant customer of Russian energy products. The EU consumes 50% of Russia’s LNG exports and 35% of its pipeline gas exports, via the Turkstream pipeline system.[vi]  In 2023, 32% of the Russian budget revenues came from oil and gas; all EU countries must understand that the rubles from these sales can be used to import Iranian drones and missiles that indiscriminately kill thousands of civilians in Ukraine.[vii] The largest EU consumers of Russian gas are Slovakia and Hungary.[viii];[ix] Significantly, Hungary has a long-term contract with Gazprom, the Russian state-owned natural gas provider, until 2036 which directly contravenes the RePowerEU plan. Despite successes with REPowerEU over the past few years, EU member states purchasing gas via the Turkstream pipeline continue to undermine EU security goals by supporting the Russian economy, government, and war efforts. The critical questions that EU policymakers now face are whether sanctions can: 1) affect change in regime behavior, 2) hinder the war-making capacity of a hostile power, and 3) be properly enforced. While the morality of sanctions on Russia is clear, scholars are divided on their effectiveness. The debate centers on whether bad actors such as China and Iran can mitigate the impact of export controls by selling Russia dual-use technologies.[x] Furthermore, the Russian economy is both large and well prepared for sanctions.[xi] EU sanctions have impacted the Russian treasury and economy in the past, but their slow pace of implementation, paired with the EU’s indecisiveness, has weakened their ability to deter and degrade the Russian capacity to invade Ukraine.[xii] 

The EU has the capacity to implement these measures, but it will be difficult. For the REPowerEU updates to take effect, they must pass the European Parliament (EP). Sanctions enforcement with LNG will be especially challenging because the Russian State will go to extreme lengths to evade their consequences.[xiii] For example, Russia could expand its Shadow Fleet operations to include the illegal transportation of LNG. The Russian Shadow Fleet is made up of hundreds of oil tankers that have fake identification documents, no insurance, and frequently change their country of registration.[xiv] This strategy allows them to evade European and American sanctions on Russian oil and potentially sell oil to European customers. Russia could also expand its use of friendly third parties to mask the origin of the Russian LNG. These necessary sanctions will require skillful diplomacy from the European Commission and national leaders. Countries such as Hungary and Slovakia will resist the end of gas imports, so overcoming these objections in the EP will be a major challenge for European Commission President Ursula von der Leyen. If EU leaders deliver the RePowerEU and implement sanctions, the economic pressure it will put on Russia can both free the EU from the shackles of Russian blackmail and degrade Russian finances used for the war.

These decisive actions will finally end the poisonous politics brought by the presence of Russian energy in the EU. The end of pipeline natural gas is especially significant as these energy streams are not easily diverted. By removing 288 million euros a month of exports and removing a major customer of Russian LNG, this would be a major, direct hit to the Russian state’s finances.[xv] The greatest challenges to these sanctions will be overcoming both the Hungarian and Slovak opposition, as well as opposition within the upcoming negotiations between the European Commission and the European Parliament. [xvi] Ultimately, the most recent sanctions package and the upcoming legislation on Russian gas imports are both critical to Russia’s wartime success; if the EU wants the war to end, it should decisively and uniformly act on passing an updated REPowerEU. Once the EU is free of Russian gas, it can truly commit to aiding the Ukrainian war effort and opposing Russia’s coercion against EU members.


[i] Ursula von der Leyen, speech, European Commission Press Corner, “Speech 22 5389” (April 2022), accessed October 6, 2025, https://ec.europa.eu/commission/presscorner/detail/it/speech_22_5389.

[ii] European Commission, *REPowerEU* (web page), accessed October 6, 2025, https://commission.europa.eu/topics/energy/repowereu_en.

[iii] European Commission, “EU Adopts New Sanctions against Russia,” October 23, 2025, https://commission.europa.eu/news-and-media/news/eu-adopts-new-sanctions-against-russia-2025-10-23_en.

[iv] European Commission, “REPowerEU,” accessed November 2, 2025. https://commission.europa.eu/topics/energy/repowereu_en.

[v] https://ukraine.ohchr.org/en/Ukraine-s-Civilians-Face-Daily-Death-and-Injury-Amid-Intense-Attacks-UN-Human-Rights-Monitors-Say.

[vi] Centre for Research on Energy and Clean Air, “August 2025 — Monthly Analysis of Russian Fossil Fuel Exports and Sanctions,” September 11, 2025, accessed October 6, 2025, https://energyandcleanair.org/august-2025-monthly-analysis-of-russian-fossil-fuel-exports-and-sanctions/.

[vii] Vitaly Yermakov, “Follow the Money: Understanding Russia’s Oil and Gas Revenues,” Oxford Energy Comment (Oxford: Oxford Institute for Energy Studies, March 2024), https://www.oxfordenergy.org/wpcms/wp-content/uploads/2024/03/Follow-the-Money-Russian-Oil.pdf.

[viii] International Energy Agency, “Hungary: Energy Mix,” accessed October 6, 2025, https://www.iea.org/countries/hungary.

[ix] International Energy Agency, “Slovak Republic: Energy Mix,” accessed October 6, 2025, https://www.iea.org/countries/slovak-republic/energy-mix.

[x] Itskhoki, Oleg, and Elina Ribakova. “The Economics of Sanctions: From Theory into Practice.” Brookings Papers on Economic Activity, Fall 2024: 425-470.

[xi] Ibid.

[xii] Ibid.

[xiii] The Flashing Red Threat from Russia’s Dark Fleet.” The Economist, September 30, 2025. https://www.economist.com/international/2025/09/30/the-flashing-red-threat-from-russias-dark-fleet.

[xiv] Ibid.

[xv] Centre for Research on Energy and Clean Air, “August 2025 — Monthly Analysis of Russian Fossil Fuel Exports and Sanctions,” September 11, 2025, accessed October 6, 2025, https://energyandcleanair.org/august-2025-monthly-analysis-of-russian-fossil-fuel-exports-and-sanctions/.

[xvi] Aura Sabadus, “Europe Finally Moves to Ban Russian Gas but Potential Loopholes Remain,” Atlantic Council (blog), October 23, 2025, https://www.atlanticcouncil.org/blogs/ukrainealert/europe-finally-moves-to-ban-russian-gas-but-potential-loopholes-remain/.


ABOUT THE AUTHOR(S)

Lucas Vroege

Lucas is a GGPS student focusing on energy political economy and holds dual US-Netherlands nationality.

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