Dual-use goods explained
Dual-use goods can serve civil and military purposes — a chip in a washing machine or in a missile, a camera on a building site or on a drone. Their export is controlled by technical parameters, not by customs tariff numbers. This section explains how that works and how to check a product.
One product, two separate checks
- What decides
- The customs tariff number (HS / CN code)
- Question it answers
- May these goods go to this country (e.g. Russia)?
- Example
- HS 8542.31 is on the EU high-priority list: banned for Russia
- Where to look
- Sanctions regulations and their annexes
- Who classifies
- You, with the tariff number of the goods
Sanctions
- What decides
- Technical parameters (performance, frequency, encryption …)
- Question it answers
- Does this product need an export licence — for any destination?
- Example
- A chip is listed under 3A001 only if, e.g., it is radiation-hardened
- Where to look
- Dual-use list: EU Annex I, Swiss GKV Annex 2, UK list, US CCL
- Who classifies
- You, with the data sheet — or the authority on request
Dual-use export control
| Sanctions | Dual-use export control | |
|---|---|---|
| What decides | The customs tariff number (HS / CN code) | Technical parameters (performance, frequency, encryption …) |
| Question it answers | May these goods go to this country (e.g. Russia)? | Does this product need an export licence — for any destination? |
| Example | HS 8542.31 is on the EU high-priority list: banned for Russia | A chip is listed under 3A001 only if, e.g., it is radiation-hardened |
| Where to look | Sanctions regulations and their annexes | Dual-use list: EU Annex I, Swiss GKV Annex 2, UK list, US CCL |
| Who classifies | You, with the tariff number of the goods | You, with the data sheet — or the authority on request |
The lists
- EU: Regulation (EU) 2021/821, Annex I — a licence is needed to export listed items out of the EU.[1]
- Switzerland: Goods Control Ordinance (GKV), Annex 2 — a licence is needed for listed goods, whatever the destination.[2]
- United Kingdom: the UK Strategic Export Control List.[3]
- United States: the Commerce Control List; each item has an Export Control Classification Number (ECCN), unlisted items subject to US rules are “EAR99”.[4]
All four share the same structure: they implement the lists agreed in the Wassenaar Arrangement and the other international export-control regimes.[5]
The ten categories
Check a product
Questions
What are dual-use goods?
Goods, software and technology that can be used for both civil and military purposes — for example certain chips, lasers, machine tools or navigation receivers. Their export needs a licence when they meet an entry of the dual-use list or when a military or weapons-related end use is known.
Can I tell from the HS code whether a product is dual-use?
No. The HS code describes what a product is for customs; the dual-use list describes what it can do, by technical parameters. Two products with the same HS code can fall on different sides. Sanctions such as the EU high-priority list, however, do apply by HS code.
Who classifies my product?
The exporter, using the product's technical data — often with the manufacturer's classification. In case of doubt, the export-control authority (SECO in Switzerland, BAFA in Germany, ECJU in the UK, BIS in the US) can classify it on request.
Sources
- [1]European Union: Regulation (EU) 2021/821 — EU dual-use regulation, Annex I (as amended by Delegated Regulation 2025/2003) (Annex I in force 15 Nov 2025).
- [2]Swiss Federal Council: Goods Control Ordinance (GKV), SR 946.202.1 — Annex 2 (dual-use goods) (status 1 Jul 2026).
- [3]Export Control Joint Unit (UK): UK Strategic Export Control Lists — consolidated list of strategic military and dual-use items (16 Dec 2025).
- [4]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
- [5]The Wassenaar Arrangement: Control lists.