Russian gas returned to Europe through the back door

Indirect routes, blending at Turkish terminals, and an embargo that exists on paper more than on invoices.

The embargo exists, it has a regulation number and a published calendar. The gas keeps arriving. Both things are true at once, and the distance between them is not an enforcement failure: it is the shape a rule takes in front of a market organised by contract rather than by origin.

Regulation (EU) 2026/261, adopted on 26 January 2026 and applicable since 18 March, bans imports of Russian gas by pipeline and in the form of LNG in stages. The Commission set the calendar precisely: short-term contracts end on 25 April 2026 (LNG) and 17 June (pipeline); long-term contracts end on 1 January 2027 (LNG) and 30 September 2027 (pipeline, extendable to 1 November if storage levels demand it).

The text does something that deserves a slow reading: it bans not the molecule but the Russian content in blends. And to make that applicable it created prior authorisation with traceability — each member state verifies the country where the gas was produced before authorising entry; the importer declares the liquefaction facility, the first port of loading and, in the case of a blend, the share of each origin. The Strandzha 1 interconnection point on the Turkish-Bulgarian border is treated as suspect by definition: presumed Russian unless proven otherwise.

The problem starts where the European customs service ends

Turkey does not apply European sanctions. Its foreign ministry is explicit: Ankara enforces only what the UN Security Council adopts. Brussels, as POLITICO put it, has zero jurisdiction over Turkish customs.

That matters because a known swap mechanism exists. Under the agreement between Bulgarian Bulgargaz and Turkish state company BOTAŞ, LNG cargoes ordered by Bulgaria are delivered to Turkey and returned to Bulgaria at the EU border. The analyst Aura Săbăduș, of ICIS, describes what is left unanswered: nobody knows whether the gas delivered is the same gas that reached the terminal. Turkish law explains the rest — all gas entering the country passes automatically into BOTAŞ ownership, according to CREA and the Center for the Study of Democracy, which allows surplus Russian volumes to be resold to south-eastern Europe under the name of Turkish blend.

A certificate of origin attests to the paperwork, not the molecule: whoever holds the right route and the right signature sells Russian gas without writing the word Russia anywhere.

What the numbers show when you look at the entry points

ACER, the European regulator and therefore the least comfortable source for either side, recorded the effect of the new regime exactly at the Turkish entry point: a fall of about 65% year on year in Russian pipeline flows via Türkiye between 18 March and 31 May 2026.

At the same time, TurkStream is the last major active land route, with about 16 billion cubic metres in 2025 — roughly 3 billion of that heading to Serbia, Bosnia-Herzegovina and North Macedonia. And for 2026 ACER counts 45 to 55 billion cubic metres a year of authorised contracted capacity, between LNG and pipeline. The same agency admits the analytical limit that matters: Russian gas imported is not necessarily consumed where it enters, because the market is integrated and the molecule circulates.

On the LNG side, the record is the most uncomfortable figure. In the first half of 2026 the Union imported record volumes from the Yamal project — more than 97% of deliveries went to European ports, according to Urgewald, and the value paid in the half-year reached about €5.96 billion, as reported by Reuters. The KSE Institute records that in June, 55% of cargoes travelled on ships managed outside EU and G7 jurisdictions — twice the previous quarter’s average — and that May brought the first documented forged flag in Russian LNG shipping.

An embargo applied in stages gives everyone two deadlines

The staged design has a rarely discussed consequence: while the long date is pending, every economic agent has an incentive to maximise volume before the cut, not to reduce it. That is what the first half of 2026 showed in Yamal.

And there is a declared loophole. The 21st sanctions package, in July 2026, while tightening the ban on terminal services, opened a temporary one-year exemption, subject to reporting, for transfers of Russian LNG to third countries. A regime with an expiry date and an exception clause is not the same thing as the end of supply — it is scarcity management.

Official accounting does not close the gap on its own: ACER’s tables attribute volumes to the member state where the gas was released for free circulation, not to the ultimate origin of the molecule blended in Turkey. In the public databases consulted, no cut isolates that phenomenon. Which means Europe’s official Russian-dependency figure is, in all likelihood, a floor — and the difference between what enters and what is counted as Russian will not be settled by statistics, but by a political decision in Ankara that has so far shown no sign of being taken.