Canada issues Russia sanctions advisory clarifying key effective dates and wind-down exceptions

OTTAWA, September 25, 2025 — Global Affairs Canada on Thursday issued an advisory clarifying the coming-into-force dates and exception periods for several trade measures added to the Special Economic Measures (Russia) Regulations in June 2025, giving importers, exporters and compliance teams a more precise roadmap for applying Canada’s Russia sanctions.

The advisory says prohibitions covering coal, jet fuel and additives, newly added industrial goods, metals and other revenue-generating goods all took effect on Aug. 12, 2025, or 60 days after the regulations were registered on June 13, 2025. Prohibitions on related chemicals and goods tied to chemical and biological weapons took effect earlier, on July 13, 2025, or 30 days after registration.

Global Affairs Canada also spelled out how transitional exceptions should be read. For several of the new measures, contracts had to be entered into before June 13, 2025, while goods or related activity had to be completed by Dec. 10, 2025, to fall within the exception. In some cases, including certain coal, metals and revenue-generating goods restrictions, the advisory says goods must also have been exported from Russia before June 13, 2025, to qualify.

The guidance matters because Canada’s June 2025 package was one of its largest Russia sanctions rounds since the start of Moscow’s full-scale invasion of Ukraine, adding broad new trade restrictions alongside designations of individuals, entities and vessels. The June package included nearly 1,000 new trade-controlled items and was framed by Ottawa as part of a broader G7 effort to raise economic pressure on Russia.

For businesses, the advisory does not create new sanctions but reduces ambiguity around when the restrictions began and whether legacy contracts or shipments can still rely on the built-in exceptions.