Goods · Dual-use

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

Sanctions

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

Dual-use export control

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
Two separate checks. A product can be free of one and caught by the other — so both always have to be answered.

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

  1. 0Nuclear materials, facilities and equipment
  2. 1Special materials and related equipment
  3. 2Materials processing
  4. 3Electronics
  5. 4Computers
  6. 5Telecommunications and information security
  7. 6Sensors and lasers
  8. 7Navigation and avionics
  9. 8Marine
  10. 9Aerospace and propulsion

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. [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. [2]Swiss Federal Council: Goods Control Ordinance (GKV), SR 946.202.1 — Annex 2 (dual-use goods) (status 1 Jul 2026).
  3. [3]Export Control Joint Unit (UK): UK Strategic Export Control Lists — consolidated list of strategic military and dual-use items (16 Dec 2025).
  4. [4]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
  5. [5]The Wassenaar Arrangement: Control lists.

General information on how export controls work — not legal advice and not an export-control classification. Classification needs the product's technical data; the official texts and the competent authority prevail.

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