Source: European Parliament
There is no general exemption for critical economic, infrastructure-related or climate-related situations from EU restrictive measures (sanctions).
The sanctions regulations need to specifically foresee an exception for such situations in each provision in order to temporarily stop the application of the specific measure in question. There are exceptions that need an assessment by the competent authority of a Member State in order to grant an authorisation, others apply without additional steps if such situations arise.
Member States are responsible for the implementation and enforcement of EU sanctions. The Commission oversees the uniform implementation by Member States, including exceptions. The Commission can also launch an infringement procedure against Member States for failure to comply with their obligations under EU law, including for the misapplication of EU sanctions.
Should there be an identified need to suspend or lift measures to respond to a critical economic, infrastructure-related or climate-related situation and the sanctions regulations do not foresee a specific exception, such an exception could be introduced by Member States acting unanimously in a same manner as for other decisions concerning EU restrictive measures.