Published
04/23/2026, 14:29The European Union’s initiative to apply the Article 12f mechanism against a third country for the first time—with Kyrgyzstan potentially becoming the first case—could affect not only re-exports but also the republic’s domestic supply chains. This view was expressed by economist Iskender Sharsheev in a comment to “Akchabar”.
According to Reuters, as part of its 20th sanctions package, the EU is considering the possibility of invoking the mechanism against circumvention of restrictions — Article 12f — for the first time with regard to Kyrgyzstan. Restrictions on the supply of certain sensitive goods to the republic, including CNC machine tools and communications equipment, are under discussion. A decision is expected to be made as early as today.
According to Sharsheev, the potential risks are linked not only to a possible decline in the re-export of European goods but also to the threat of disruptions to the domestic market, especially in sectors dependent on imported equipment and components.
“In many industries, Kyrgyzstan uses European equipment—including German, Swiss, and Austrian—in processing, the food industry, and the production of dairy products, juices, and sausages. Even if the restrictions affect not the production lines themselves but spare parts, consumables, and individual components, this could lead to increased business costs, complicate equipment maintenance, and reduce production stability,” the expert notes.
At the same time, according to the economist, a more sensitive scenario may not be direct EU export controls, but a secondary effect, where suppliers from other countries begin to exercise caution.
“There is a risk that Chinese manufacturers, especially those using European components or fearing secondary sanctions, may also begin to restrict the supply of certain types of equipment to Kyrgyzstan. Such a scenario could potentially prove even more damaging,” Sharsheev believes.
He added that similar cautious behavior by certain Chinese companies has been observed before, so the risk cannot be considered purely theoretical.
At the same time, the expert noted that the very choice of Kyrgyzstan as the first case for applying the mechanism against sanctions circumvention raises questions, given the country’s relatively small share in global goods logistics
“We’re not even talking about 5%. Why is this mechanism supposed to be applied for the first time specifically to Kyrgyzstan, rather than to much larger transit jurisdictions?” concluded economist Iskender Sharsheev.
If the Article 12f mechanism is applied, it will set a precedent for the first use of this tool against sanctions evasion involving a third country.
