Goods · Dual-use · Is my product controlled?

Is my product export-controlled?

Five questions, in this order. Each one can stop a shipment on its own — a “no” at one step does not answer the next.

The five steps

  1. 1

    Is the destination, the buyer or the route under sanctions?

    Embargoes and country measures, listed parties, transit and re-export countries.

    Check a shipment →
  2. 2

    Is the HS code named in a sanctions measure?

    For example the EU high-priority list and the Russia and Belarus annexes — these apply by tariff number, whatever the specifications.

    High-priority goods →
  3. 3

    Does the product meet an entry of the dual-use list?

    Compare the data sheet with the list (EU Annex I, Swiss GKV Annex 2, UK list, US CCL). If yes, an export licence is needed — in the EU and Switzerland for any destination outside the respective area.

    How control numbers work →
  4. 4

    Even if not listed: could the end use be military or weapons-related?

    “Catch-all” rules: a licence can be required for unlisted goods if you know or are told of a military end use in an embargoed country or a link to weapons of mass destruction.

  5. 5

    Who is the end user, and does the story hold up?

    End-user statement, ownership, business fit, warning signs. In case of doubt, ask the export-control authority before shipping.

If a licence is needed

Licences are granted by the national export-control authority of the exporting country — SECO in Switzerland, BAFA in Germany, ECJU and OTSI in the UK, BIS in the US. Some destinations are covered by general authorisations; others need an individual licence. A licence is never automatic, and some exports (for example most goods to Russia) are banned outright.

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]Council of the EU: Council Regulation (EU) No 833/2014 (Russia) — Annexes XXIII and XL (consolidated 24 Jul 2026).
  3. [3]Swiss Federal Council: Goods Control Ordinance (GKV), SR 946.202.1 — Annex 2 (dual-use goods) (status 1 Jul 2026).
  4. [4]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
  5. [5]European Commission: Guidance for EU operators: implementing enhanced due diligence to shield against Russia sanctions circumvention (2023/2024).

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.

← Dual-use explained · High-priority goods