Last week, the European Union adopted the 20th package of sanctions against Russia — the largest in terms of individual listings in two years. For the first time, the EU’s anti-circumvention instrument was activated: Brussels restricted exports to Kyrgyzstan of goods proven to have been re-exported to Russia. The signal was unambiguous: the fight against third-country bypass schemes is entering a new phase. As EU foreign policy chief Kaja Kallas stated, preparations for a 21st package have already begun, one that will revisit previous “red lines”.
Practice, however, shows that the sanctions architecture and corporate decision-making do not always move in the same direction. It was precisely during the days when the 20th package was being finalised that it emerged that the Swiss-based global packaging manufacturer Amcor has been signing contracts in Russia.
Amcor sold its Russian plants in December 2022. The decision was presented as a responsible one: the company cited the need for a peaceful resolution to the conflict. The #LeaveRussia initiative recorded its status as “Exit Completed”.
Yet Amcor continues to operate in the Russian market. The corporation’s interests there are represented by LLC ROTI, registered by entrepreneur Ho Leva in November 2025, which has opened an office in Moscow and is building its own infrastructure, including a network of warehouse facilities.
In April, ROTI signed an agreement to supply flexible packaging and pouches to AlphaPet, a super-premium pet food manufacturer — the first Russian brand to renew its partnership with Amcor. The details of the strategic cooperation were discussed at the corporation’s Chinese office, where Amcor China Vice President Huang Hawk presented the product portfolio to the new partners.
Materials are supplied to Russian FMCG producers from Amcor’s factories in China, Thailand and the Czech Republic — the latter being an EU member state, which gives this supply chain particular legal sensitivity.
The legal position is ambiguous. The 14th sanctions package already obliged operators active within EU jurisdiction to make their “best efforts” to ensure that their foreign affiliated structures do not participate in activities that undermine the sanctions regime. EU Directive 2024/1226, which criminalised violations of that regime, sets the maximum penalty at no less than 5% of total worldwide turnover or €40 million.
ICLG experts note that beyond legal risks, reputational exposure and the evolving ethical landscape must be taken into account in any decision to resume business with Moscow. For Amcor, which publicly declared its break with Russia on ethical grounds, a return via an intermediary raises questions about the sincerity of those statements.
That said, the company’s behaviour follows a discernible commercial logic. Russia’s flexible packaging market reached 1.4 million tonnes in 2025, up 5%. One driver is the rapid growth of e-commerce, which has made courier bags, for example, the most dynamic segment — one that is attracting growing interest from Chinese players.
Russian producers risk ceding a significant share to them if they compete on cost at the expense of quality, warns Andrei Petrov, head of the Flexible Packaging division at SIBUR. “This would only sharpen competition with Chinese imports,” he said.
The broader statistics are telling: China’s share of finished polymer product imports into Russia grew from 41% in 2021 to 69% by the end of 2024 — driven largely by China’s significantly lower production costs.
In these conditions, Amcor’s approach via its Chinese factories appears far from accidental: competitively priced products, unclear legal liability, and a growing Russian market within reach — while the European market, by contrast, is cooling.
According to Allianz, in a downside scenario driven by the energy shock from the Middle East, eurozone GDP growth could fall to just 0.2% — effectively a technical recession. Against a backdrop of stagnating growth in the EU, corporations are unlikely to sacrifice profitability for geopolitical solidarity. The Amcor case is not an isolated one, but an indicator: it exposes the growing tension between Brussels’ sanctions ambitions and the commercial pragmatism of companies operating in global supply chains.
