India’s diesel exports to the European Union (EU) are anticipated to remain strong during the October to December 2025 period, prior to the imposition of the January 21, 2026 deadline under the EU’s 18th sanction package. This package is set to enhance compliance scrutiny, raise freight rates, and alter global trade routes, with a particular focus on prohibiting refined petroleum products processed from Russian crude oil in third countries as outlined in Article 3ma.
In September 2025, India’s diesel shipments to the EU reached approximately 291,000 barrels per day (b/d), marking the highest volume since December 2023. Analysts and traders attribute this increase to expectations surrounding the upcoming January 2026 deadline, predicting that diesel and jet fuel flows will remain “firm or sizeable” at least until the end of 2025.
Supply chains are expected to evolve as sanctions come into effect, a trend observed over recent years. However, this transformation is likely to incur higher freight costs and limit access to winter-grade diesel, primarily supplied to the EU by Indian refiners like Reliance Industries (RIL).
Global data and analytics provider Kpler projects that India’s refined product exports will maintain a solid footing through October to December 2025, buoyed by robust refinery operations and lighter maintenance schedules compared to the previous year. “European buyers may import in substantial volumes in anticipation of the EU’s 18th sanctions package effective in January 2026. This mirrors the stockpiling seen ahead of the 2023 Russian product ban, reaffirming India’s pivotal role as a swing supplier in global markets,” Kpler stated.
Impact of Sanctions
In its latest monthly oil market report, OPEC noted that diesel exports from India to Europe may face challenges in the future due to uncertainties surrounding the EU’s potential ban on Russian refined products. According to Sumit Ritolia, Kpler’s Lead Research Analyst for Refining & Modeling, diesel exports remain strong but have dipped below September’s peak, averaging around 195,000 b/d as of October 18. This decrease is attributed to rising domestic demand amid the Diwali festival, which tightens export availability. Additionally, some European refineries are set to restart operations in November, alleviating some product shortages.
“Flows are expected to stay robust, although they should exceed seasonal norms as long as the arbitrage remains favorable and Atlantic Basin balances are tight. Moreover, India’s demand is projected to remain high due to the festive season and GST rate cuts,” Ritolia explained.
Window of Opportunity
Regarding the enforcement of Article 3ma, Ritolia noted that Brussels has offered clarity, with the final regulations aligning closely with Kpler’s prior predictions. The European Commission has released detailed FAQs on Article 3ma, outlining how importers must demonstrate that refined products are not derived from Russian crude. Notably, bunker fuel for a vessel’s own operations and jet fuel in an aircraft’s tanks for inbound flights are exempt, but any fuel exceeding operational needs, or intended to bypass the ban, is subject to Article 3ma.
This regulatory framework could present a narrow pathway for Reliance Industries, supported by its dual-refinery structure at Jamnagar. If RIL can verify strict segregation and compliance with evidentiary standards at its 763,000 b/d export-oriented Special Economic Zone (SEZ) refinery, it can continue supplying compliant cargoes to Europe, despite Russian crude processing at its 693,000 b/d domestic tariff area (DTA) refinery.
The SEZ and DTA units function as separate entities with distinct crude pipelines, tank farms, and independent accounting. Product lines operate independently, even if they utilize a shared Single Point Mooring (SPM) for vessel loading. This setup provides RIL with genuine operational segregation and the flexibility to channel all Russian crude to the DTA unit while processing non-Russian barrels at the SEZ.
“Although such scheduling poses operational complexities, Reliance has the capabilities to execute it. If effectively implemented, this would resolve a significant layer of uncertainty regarding Q4 ultra-low-sulfur diesel supply and enhance cargo eligibility through 2026,” Ritolia concluded.
Published on October 25, 2025.
