Nearly three and a half years into the EU's sanctions campaign against Russia, the bottleneck is no longer Moscow. It is Brussels' own decision rule. The bloc's 21st sanctions package remains unagreed, EU foreign policy chief Kaja Kallas said, according to Reuters. What is stalling it is not a disagreement over whether to keep pressuring Russia — every member state says it wants that — but a set of narrow, national vetoes over specific line items.

Why one country can freeze the whole package

EU sanctions are adopted under the Common Foreign and Security Policy, the bloc's foreign-policy chapter, which by treaty requires unanimity among all 27 governments in the Council of the EU. There is no qualified-majority shortcut written into the treaties for this kind of measure — the closest thing legal scholars have proposed is a workaround invoking the EU's foundational values, but that route has never been used to force through sanctions over an explicit veto, as outlined by Verfassungsblog. In practice, that means any single capital can hold the other 26 hostage over a single clause — precisely what is happening now, and what happened repeatedly with Hungary and Slovakia over earlier rounds, who dropped their vetoes on the 20th package only after winning concessions, per Kyiv Independent.

The workflow itself runs through several layers before ministers ever vote. The European Commission drafts the package; member states' ambassadors thrash out the text inside the Committee of Permanent Representatives, known by its French acronym Coreper; and final sign-off happens at ministerial level, typically the Foreign Affairs Council, or via a written procedure among ambassadors if consensus is reached earlier. It is at the Coreper stage that this round has been stuck, with ambassadors meeting repeatedly under the Irish presidency of the Council, which took over on 1 July, to revise the text line by line.

The three fights holding up the package

Three separate disputes have merged into one deadlock. Bulgaria is objecting to two individual listings: Patriarch Kirill, head of the Russian Orthodox Church, whom Sofia frames as a religious-freedom issue, and oligarch Vagit Alekperov, founder of Lukoil, against whom Bulgaria faces a €3 billion compensation claim tied to the company's Bulgarian assets, according to Euronews. Bulgarian Prime Minister Rumen Radev put it bluntly: "We will not allow the sanctions package to pass in this form. We have a vote, and we will use it," per the same report.

Separately, France and Italy have resisted a proposed measure to deny EU entry to Russian soldiers who fought in Ukraine, while Germany, France, Poland and the Netherlands have pushed back on a planned ban on Russian fish imports — cod and pollock — that their fishing and processing industries rely on, also per Euronews. None of these objections concerns the package's headline target, Russian oil revenue and sanctions-evasion networks — they are all narrower, sector- or symbol-specific fights, which is exactly why they are proving so hard to trade away against each other.

What is being watered down

To clear Coreper, negotiators have been stripping out or softening the contested clauses rather than resolving the underlying disagreements. Patriarch Kirill and Alekperov look set to be dropped from the sanctions list entirely, according to Ukrainska Pravda, which cited sources describing the move as a concession to Bulgaria. The proposed entry ban on Russian combatants is being narrowed rather than scrapped, and the fish-import restrictions and planned curbs on Russian liquefied natural gas and associated tankers look likely to be dropped from this package altogether, per European Pravda, which reports the compromise version could go to the EU Foreign Affairs Council around 13 July.

Kirill's exclusion is the clearest marker of how this bargaining works. He was never central to the package's economic effect — sanctioning a patriarch does not touch Russian oil revenue or war financing. But he was politically cheap for the other 26 states to give up, and expensive for Bulgaria to keep fighting over. Dropping him lets Sofia claim a win on religious-freedom grounds without the EU sacrificing anything with real teeth. That is the general pattern: symbolic or narrow-interest items get traded away first, so unanimity can be bought without touching the package's substantive core.

HYPOTHESIS: The Kirill exclusion functions as a release valve — a low-cost concession that lets Bulgaria save face while preserving the harder measures on oil and evasion. Supporting this: negotiators kept the oil and financial-sector provisions in play while dropping Kirill, Alekperov, the fish ban and the LNG curbs, all narrower or sectoral items, per European Pravda. Against this: so many items were watered down simultaneously — combatant entry bans, fish, LNG, individual listings — that the pattern could equally reflect a package losing substance across the board rather than a deliberate, targeted trade-off. Watch whether the oil and financial provisions survive intact in the version put to ministers.

Why the clock matters

There is a real deadline behind the haggling. If no agreement is reached, an automatic review clause could allow the price cap on Russian seaborne oil — currently $44 a barrel — to rise, easing pressure on Moscow's oil revenue, according to Euronews. That gives every capital with a grievance leverage: the longer they hold out, the closer the EU comes to a deadline that works against its own sanctions regime by default, not by anyone's vote.

What to watch next

  • Whether the Foreign Affairs Council formally adopts the package around 13 July in the compromise form reported by European Pravda, or whether Bulgaria, France or Italy hold out for further changes
  • Whether the oil price cap and financial-sector measures survive intact once the symbolic and sectoral items are stripped out
  • Whether Hungary and Slovakia, absent from this round's public objections so far, reintroduce Druzhba-pipeline demands before final sign-off, as they did on the 20th package
  • Whether the pattern of trading symbolic listings for unanimity becomes a template EU capitals use to extract concessions on future packages

The mechanics here are not a footnote to the story — they are the story. A sanctions regime that requires 27 unanimous yeses every time gives each government a veto over the whole bloc's Russia policy, and this round shows what capitals do with that leverage: not blocking sanctions outright, but extracting narrow, often symbolic trades in exchange for letting the substantive measures through.