Sanctions Against Russia: List of Common High Priority sanctioned goods
- Arne Mielken
- Dec 19, 2023
- 4 min read
Find here the latest list of Common High Priority sanctioned goods to which businesses should apply particular due diligence and which third countries must not re-export to Russia.
This is the list of prohibited dual-use goods and advanced technology items used in Russian military systems found on the battlefield in Ukraine or critical to the development, production, or use of those systems.
In addition, within the EU, there is list of sanctioned goods that are economically critical and on which businesses and third countries should be especially vigilant.
List of Common High Priority Items (Version of September 2023)
The EU and its international partners responded to Russia’s war of aggression against Ukraine on 24 February 2022 with massive and comprehensive restrictive measures. The sectoral sanctions aim at curtailing Russia’s ability to wage the war, depriving it of critical technologies and markets and significantly weakening its industrial base. Regulation 833/2014 imposing sanctions against Russia has sharpened and includes prohibitions on the export, sale, transfer of dual-use goods and advanced technology items to target sensitive sectors in Russia’s military industrial complex and to limit its access to crucial advanced technology. The European Commission services, in coordination with the competent authorities in the US, the UK and Japan, have identified a number of prohibited dual-use goods and advanced technology items used in Russian military systems found on the battlefield in Ukraine or critical to the development, production or use of those Russian military systems. These items include electronic components such as integrated circuits and radio frequency transceiver modules, as well as items essential for the manufacturing and testing of the electronic components of the printed circuit boards retrieved from the battlefield. These battlefield items have been grouped into a list of Common High Priority Items, which can be found in the Annex. The List may support due diligence and effective compliance by exporters and targeted anti-circumvention actions by customs and enforcement agencies of partner countries determined to prevent that their territories are being abused for circumvention of EU sanctions purposes.
4 Tiers
The List of Common High Priority Items is divided into four Tiers containing a total of 45 (Harmonised System codes) dual-use and advanced technology items sanctioned under the Russia Sanctions Regulation and involved in Russian weapons system used against Ukraine, including e.g. the Kalibr cruise missile, the Kh-101 cruise missile, the Orlan-10 UAV and the Ka-52 “Alligator” helicopter.
The list is divided into four Tiers:
Tier 1 comprises four HS codes which describe integrated circuits (also referred to as microelectronics).
Tier 2 comprises five HS codes containing electronics items related to wireless communications, satellitebased radio-navigation and passive electronic components
Tier 3 is itself divided in two sets:
Tier 3.A, which comprises 16 HS codes containing discrete electronic components, electrical plugs and connectors, navigation equipment and digital cameras.
Tier 3.B, which lists nine HS codes used to export mechanical and non-electronic components, such as bearings and optical components.
Tier 4 includes 11 HS codes concerning manufacturing equipment for production and quality testing of electric components and circuits.
The List is not static and will be periodically adjusted in the light of what is found in Russian military systems on the battlefield and Russia’s use of sanctioned sensitive items. It replaces the previous version released on 23 June 2023.
Download the latest List of Common High Priority sanctioned goods
More information and links
Full Sanctions Collection
For all of the latest sanctions updates of the U.S., the EU and the UK, see our collection here:
Full Guide To EU Russia Sanctions
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