Goods · Dual-use · HS code vs. control number

HS code vs. export control number

The HS code says what a product is for customs. The control number says what it can do. One microcontroller in a washing machine and one hardened for space share HS 8542.31 — only the second may be on the dual-use list.

Two numbers, two questions

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

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

	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

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

How a control number is built

3CategoryElectronics (0–9)

AGroupSystems, equipment and components (A–E)

001NumberWassenaar range (001–099)

.a.1Sub-itemthe exact technical description

The letter: what kind of item

A — Systems, equipment and components
B — Test, inspection and production equipment
C — Materials
D — Software
E — Technology

The number: where the control comes from

001–099 — Wassenaar Arrangement (conventional arms, dual-use goods)
101–199 — Missile Technology Control Regime
201–299 — Nuclear Suppliers Group
301–399 — Australia Group (chemical and biological)
401–499 — Chemical Weapons Convention
501–599 — Controls the EU added on its own

The US uses the same structure (Export Control Classification Number, ECCN); items subject to US rules but not on the list are “EAR99”. The UK and Swiss lists follow the EU numbering.

In practice

Ask the manufacturer for the export-control classification (EU/Swiss number or ECCN) of each part — many publish it.
For your own products, compare the data sheet with the list entries of the matching category.
Use the HS code for the sanctions check: it decides, for example, whether goods are on the EU high-priority list.
In case of doubt, ask the authority for a classification before shipping.

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]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
[3]The Wassenaar Arrangement: Control lists.
[4]European Commission: List of Common High Priority Items (version of February 2024) (22 Feb 2024).