Sanctions on Trade with Israeli Settlements in the West Bank

An overview of the measures announced on September 8, 2026, the participating countries and implementation dates, and potential repercussions for Israeli companies.

On September 8, 2026, the foreign ministers of twelve countries issued a joint statement concerning trade restrictions on goods from Israeli settlements in the West Bank. Three signatories—the UK, France, and Canada—announced their intention to impose national import bans. Five European countries have already implemented such measures.

The restrictions take effect at different times:

• Already in effect: Spain, Belgium, and Norway have imposed restrictions. Ireland has enacted a ban, but it will take effect only upon the issuance of commencement orders.
• September 22, 2026: The Netherlands ban will take effect in two weeks. This is the most urgent deadline for exporters.
• Six to nine months: This is the expected time frame for the UK’s new sanctions regime to take effect. It is the most extensive regime and also covers services and advertising.

Key points about the sanctions:

• The sanctions apply only to goods originating in Israeli settlements. They do not apply generally to goods from the West Bank or to trade with Israel within the Green Line.
• The countries’ sanctions are not uniform in terms of geographic scope.
• The UK also announced a ban on services and advertising.

This update reviews the countries involved and the relevant implementation dates, the three components of the UK’s sanctions package, and the significance of Israel’s E1 settlement project east of Jerusalem. It also maps sector-specific sanctions exposures and sets out recommendations for Israeli manufacturers, including a recommended action schedule for the next fourteen days.

Countries and Implementation Dates

Because the geographic scope of the restrictions is not uniform, Israeli companies must review the definitions in each country’s sanctions regime. The Netherlands decree applies to Israeli settlements in territories that the Netherlands does not recognize as Israeli territory, including the Golan Heights. It applies to persons located in the Netherlands, as well as Dutch citizens and companies operating outside the Netherlands. The Irish law applies to the West Bank and East Jerusalem.

The UK’s Sanctions Package

British Foreign Secretary Ed Miliband presented the package to the House of Commons on September 8, 2026:

1. Sanctions with immediate effect

• Sanctions have been imposed on a group of named Israeli settlers who allegedly supported or incited violence against Palestinian communities.
• Expansion of the UK’s existing sanctions regime, whose stated purpose is to protect “global human rights,” so that any action to expand Israeli settlements may constitute grounds for imposing sanctions. This would enable faster action against settlement expansion, including Israel’s E1 settlement project.
• Rejection of all export-license applications for weapons and other goods that “materially contribute to the occupation.” Foreign Secretary Miliband described this as a “double-lock”: first, a ban in effect since September 2024 on all defense exports used by the IDF in Gaza; and second, a ban on all exports of weapons, goods, and services that “materially contribute to the occupation.” The second ban will remain in effect for as long as Israel continues its occupation of the West Bank.

2. Legislative measures expected to take effect within six to nine months

• Ban on imports of goods from Israeli settlements.
• Ban on the provision of construction, infrastructure, financing, and real estate services to companies and individuals for the purposes of expanding settlements.
• Ban on advertising Israeli settlements in the UK. The measure follows a real estate event held in London earlier this year that marketed land in Israeli settlements.

These three bans will be included in a new comprehensive sanctions regime, with appropriate religious exemptions. The scope of the exemptions will be specified in regulations.

3. Change in legal position

For the first time, the UK declared that it considers Israel’s control over the entire West Bank to constitute an unlawful occupation. This position may have far-reaching implications for legal opinions, insurance underwriting, and contractual representations. However, Foreign Secretary Miliband also stated that the UK would continue to trade with Israel within the Green Line and opposes the boycott movement.

4. Enforcement

HM Revenue and Customs is responsible for enforcing the ban on goods at the border. The UK Department for Business and Trade is responsible for enforcing sanctions relating to civilian trade and services. HM Treasury is responsible for enforcing financial sanctions. 

5. Israel’s E1 Settlement Project

The joint statement expressly identifies the publication of tenders for Israel’s E1 settlement project as one reason for the measures. The UK has expanded its global human rights regime to enable rapid sanctions against entities involved in expanding Israeli settlements and has specifically named the E1 settlement project. Involvement in infrastructure, earthworks, or construction projects in the area is a high-priority criterion for designating developers and contractors for sanctions.

Exposures to Sanctions by Sector

1. Manufacturers and exporters

This sector faces immediate exposure. The Netherlands decree prohibits not only imports, but also purchases and sales of the relevant goods and the provision of brokerage services relating to them. It also contains an express anti-circumvention provision, a breach of which may result in criminal liability. Manufacturers and exporters must accurately identify products’ origin by the effective date. When the UK regulations take effect, goods from Israeli settlements will be blocked at the UK border.

For products manufactured in the West Bank and shipped through Israel to other countries, the relevant rules of origin under applicable customs regimes and export restrictions will apply. In principle, a product is considered to originate in a particular location only if it undergoes substantial transformation or processing there. Merely shipping a product manufactured in the West Bank through Israel, without substantial processing in Israel, will not change its origin.

2. Construction, earthworks, and infrastructure contractors

Companies carrying out development, paving, or construction work at particular sites in the West Bank face a direct risk of being designated as sanctioned entities. They also risk having end-user licenses for UK or European heavy-engineering equipment, parts, and software revoked.

3. Real estate, marketing, and advertising

This is the most significant innovation in the UK’s sanctions package. The ban on advertising in the UK will apply to the marketing of land and apartments in Israeli settlements. Spain already prohibits advertising Israeli tourism services in the West Bank. Companies operating in these markets should therefore review both their commercial activities and how those activities are marketed, including through websites, conventions, and advertisements. They should also review the status of local agents and marketers.

4. Banking and finance

The measures do not affect routine banking activities involving consumers. Exposure arises in connection with project financing, Sales Law guarantees, and real estate development bond issuances relating to Israeli settlements in the West Bank. The UK’s ban on financing services applies to British entities. Israeli financial institutions face indirect exposure through correspondent bank requirements, contractual representations, and compliance provisions, as well as direct exposure to designation risk.

5. Importers of UK equipment and technology

The UK’s “double-lock” operates in the opposite direction to that commonly assumed. It restricts UK exports to Israel, rather than Israeli exports to the UK. Israeli companies that rely on UK components, parts, or software should map that dependency and consider alternatives.

6. Types of trade not affected by the sanctions

Trade with Israel within the Green Line continues as usual. Healthcare services, pharmaceuticals, and food for the civilian population are not affected by these measures. The UK has announced religious exemptions, the scope of which will be defined in future regulations.

Operative Recommendations to Israeli Manufacturers

1. Map the sources of goods in the supply chain according to the actual production facility rather than the registration address. The mapping should include raw materials and packaging facilities.
2. Ensure that every shipment to the Netherlands market is supported by an accurate declaration of origin.
3. Review marketing and advertising materials distributed in the UK and Spain, and review the status of local marketers.
4. Review sanctions stipulations in financing contracts and in international credit lines, especially provisions specifying grounds for immediate repayment.
5. Consider restructuring activities to separate core operations from your operations beyond the Green Line. Any restructuring must be carefully designed: a separation that does not reflect a genuine economic change could be treated as circumvention, which is expressly prohibited under the Netherlands decree.
6. Map dependency on imports under British export licenses.
7. Prepare for public tenders in Europe. The Netherlands decree also applies to public procurement bodies, which must verify a product’s origin throughout the supply chain.

Recommended Actions for the Next Fourteen Days

Documents

•  Joint Statement of the Foreign Ministers, September 8, 2026:
• The Netherlands’ decree, the government’s announcement:
• Netherlands customs guidelines for importers and exporters:
• Netherlands Enterprise Agency’s guidelines for businesses:
• Ireland’s Law, the official legislative page:
• The UK’s Sanctions List:

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This update presents general information and an assessment of the situation. It does not constitute a legal opinion about the circumstances of any specific case. Some of the measures described have not yet been anchored in a binding legal instrument.

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Prof. Amichai Cohen is a special counsel on International Law in the firm.