Netherlands Imposes Sanctions on Israeli Settlement Products: Dutch Customs Requirements for Imports from Israel

The Temporary Sanctions Order on Goods from Israeli Settlements in Israeli-Controlled Territories (Tijdelijk sanctiebesluit onrechtmatige nederzettingen, Stb. 2026, 222) took effect on September 22, 2026. The Order prohibits imports, purchases, and sales of goods that are wholly or partially produced in Israeli settlements in Israeli-controlled areas since the Six-Day War, including the Golan Heights. It also prohibits the provision of intermediary trading services for these goods, as well as any action intended to circumvent the prohibitions. The Order came into effect without any transitional period and also applies to inventory already in the Netherlands.

Discussion in Israel has focused on companies operating beyond the Green Line. In practice, however, the Order places a burden on all exporters from Israel to the Netherlands. According to Dutch customs guidelines, Dutch importers must declare, for every shipment from Israel, that the goods are not from Israeli settlements and must provide supporting evidence during audits. Since the prohibition also applies to goods partially produced in Israeli settlements, it covers not only the product’s assembly location but also the origins of its components. Dutch importers are likely to pass these requirements on to Israeli exporters. In other words, for most Israeli exporters, the main practical requirement arising from the Order is to document production locations.

This update outlines the changes introduced by the Order, the timetable, the sectors most affected, and the measures exporters should take now.

The Situation Until Now and What Is Changing

Until the Order came into effect, products from Israeli settlements could lawfully be sold in the Netherlands, subject to two restrictions under European law: exclusion from preferential treatment under the EU-Israel Association Agreement and the obligation to label products with their precise origin. The Order moves from origin labeling to a prohibition and imposes an evidentiary burden on all shipments from Israel.

Israeli settlements are identified using the EU’s list of postal codes, which has long been used to exclude settlement goods from preferential tariffs. The Order clarifies that it does not change trade relations between the Netherlands and Israel within its 1967 borders and that it applies solely to goods. The Dutch government stated that it found no basis in European law for imposing a national ban on services and investments, which fall within the EU’s exclusive authority over trade policy, and that it continues to explore possibilities in this regard. Enforcement is delegated to the Customs Authority for imports and to the Fiscal Information and Investigation Service (FIOD) for other prohibitions.

Timetable

The Order was signed on July 13, 2026, and published on July 21, following an urgent opinion issued by the Netherlands Council of State on June 24. It was enacted pursuant to Article 2(1) of the Sanctions Law of 1977 (Sanctiewet 1977), which authorizes the government to implement the recommendations of international organizations through sanctions orders. The government relied on the International Court of Justice’s July 2024 advisory opinion and resolutions of the UN General Assembly and Security Council. The Order came into effect two months after publication and will expire after three years, on September 22, 2029, unless extended or repealed earlier by law.

Upon publication, the Dutch government informed parliament that either house could, by September 30, 2026, demand that the Order be ratified by law, and that rejection of ratification following such a demand would result in the Order’s immediate repeal.

The Order took effect on September 22, 2026, and will expire in 2029 unless extended.

Israeli Sectors Impacted by the Order

According to data from the UN Comtrade database, Israeli exports to the Netherlands totaled about USD 2.66 billion in 2025, or about 4.5% of Israel’s total goods exports, compared with about USD 2.70 billion in 2024. These exports are diverse and largely industrial, with seven sectors accounting for about 75% of Israel’s exports to the Netherlands: machinery and mechanical devices; fuels and distillates; chemicals and fertilizers; optical and medical devices; agriculture and food, including processed foods; electrical equipment; and plastics.

The sectors most directly impacted by the Order appear to be agriculture and food, as well as smaller sectors such as cosmetics (about USD 20 million) and wine, since some production operations are located beyond the Green Line or in the Golan Heights. Exporters that market produce from both sides of the Green Line must keep it separate at every stage of the supply chain, including in packing houses, and document that separation. For Israel’s industrial sectors, the risk is more indirect but broader: products assembled inside the Green Line may contain a component from a sub-supplier located in an industrial zone beyond the Green Line. Dutch importers will likely require declarations addressing this risk. The Dutch customs guidelines also suggest that major, regular Israeli suppliers will need to provide highly detailed documentation.

Two additional categories of Israeli companies are directly affected. The first consists of Israeli companies with Dutch subsidiaries. According to the FAQs published by RVO, the Netherlands Enterprise Agency, the Order applies to all companies in the Netherlands and to Dutch companies in all EU countries. The prohibition on intermediary services may also apply to sales and marketing activities involving goods that do not physically transit through the Netherlands. The second category consists of Israeli exporters and logistics companies that route goods through the port of Rotterdam to other EU member states. Transit itself is permitted, but only while the goods remain under customs control and are not released onto the Dutch market.

Measures Israeli Companies Should Take

1. Map your supply chain down to the component level. Identify the production, cultivation, and packaging sites for every product sold to the Netherlands, as well as the sites of sub-suppliers of material components, and check their postal codes against the EU’s list. A single site beyond the Green Line in a supply chain can put an entire shipment at risk.
2. Prepare and maintain evidence dossiers for Dutch importers. The Dutch Customs Authority accepts supplier certificates or declarations specifying the postal code or production location; invoices, contracts, and logistics documents identifying the production site; and manufacturers’ declarations that the product was manufactured within Israel’s 1967 borders. We recommend preparing a standard evidence packet for each product and checking that it is consistent with the evidence of origin provided under the Association Agreement.
3. Review declarations and indemnity clauses in contracts. Dutch importers are likely to require signed declarations and indemnity clauses. Before signing, make sure the declarations do not go beyond what supporting documentation can substantiate, especially regarding components from sub-suppliers. Clarify who bears the costs of a detained shipment, unsellable inventory, and seized goods.
4. Review activities in the Netherlands. Companies with a Dutch subsidiary, a distribution center in Rotterdam, or a Dutch sales agent should assess whether their activities involve products prohibited by the Order, even when those products do not reach the Dutch market. The Dutch entity bears criminal liability, which may require the parent company to adjust its operations.

These measures do not resolve all issues. The level of enforcement in practice will become clear only as the Dutch Customs Authority begins requesting documents, and the Order may be amended during its three-year term. Nevertheless, Israeli exporters to the Dutch market should begin preparing the required documentation now.

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Prof. Amichai Cohen is a special counsel for international law.