Goods · EU high-priority items

Exporting ball and roller bearings: sanctions risk

Ball bearings and tapered, spherical and cylindrical roller bearings.

These 4 HS codes are on the EU list of Common High Priority items: goods found in Russian weapons, identified by the EU together with the US, the UK and Japan.

What they are — and the two lives of a component

This group covers ball bearings (HS 8482.10), tapered roller bearings (8482.20), spherical roller bearings (8482.30) and other cylindrical roller bearings (8482.50). Bearings let shafts and wheels turn with little friction and are found in almost every machine.

Civil uses

  • Cars, trucks and railway wheelsets
  • Industrial motors, pumps and gearboxes
  • Wind turbines and generators
  • Machine-tool spindles
  • Aircraft engines and landing gear
  • Household appliances

Documented military uses

  • Mechanical components of Russian weapons systems (listed as such on the CHP list)[1]
  • Among the war-critical goods Russia still imports, mostly via third countries[2]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

Bearings are Tier 3 of the Common High Priority list — mechanical components used in Russian weapons systems. Bearings and transmission shafts made up about 6 % of the value of critical components Russia imported in January–October 2023, most of them through third-country intermediaries.[1][3][2]

This group: Tier 3 of 4

  1. Tier 1Chips
  2. Tier 2Radio, navigation, capacitors
  3. Tier 3◀ this groupOther electronics, mechanical and optical parts
  4. Tier 4Machines to make and test
The authorities rank the 50 goods on the list by how urgently they want to keep them from Russia's military. All four tiers are restricted — the tier only says where to look first.

Which measures apply

  • ● Yes = applies to these HS codes
  • ◐ Check = applies only in part or with conditions — check the rules
  • ○ No HS rule = no rule by tariff number (other rules can still apply)
RegimeExport to Russia bannedExport to Belarus bannedExport to Iran restrictedExtra due diligenceRe-export safeguards
European UnionYes[4]Yes[5]No HS rule[6]Yes[7]Yes[4]
SwitzerlandCheck[8]Check[9]Check[9]Check[8]Check[8]
United KingdomYes[3]Check[3]Check[3]Yes[3]Check[10]
United StatesYes[11]Yes[11]Check[1]Yes[1]Yes[11]
Details per cell
  • EU · Export to Russia banned: Annex XL items; export ban (Art. 2, 2a)
  • EU · Export to Belarus banned: Annex XXX items; export bans (Art. 1e, 1f)
  • EU · Export to Iran restricted: Not in the Iran drone/missile annex — other Iran rules may apply
  • EU · Extra due diligence: Art. 12gb: documented risk assessment and controls
  • EU · Re-export safeguards: Art. 12g: contractual “no-Russia” clause
  • Switzerland · Export to Russia banned: Annex 1 published by reference — check the regime's rules
  • Switzerland · Export to Belarus banned: check the regime's rules
  • Switzerland · Export to Iran restricted: check the regime's rules
  • Switzerland · Extra due diligence: Annex 31 high-priority goods — check the regime's rules
  • Switzerland · Re-export safeguards: Art. 14f “no-Russia” clause for Annex 31 goods
  • UK · Export to Russia banned: All CHP list items are subject to UK sanctions
  • UK · Export to Belarus banned: check the regime's rules
  • UK · Export to Iran restricted: check the regime's rules
  • UK · Extra due diligence: UK CHP list; due diligence expected
  • UK · Re-export safeguards: Indirect supply via third countries prohibited
  • US · Export to Russia banned: Licence required for these HS codes (EAR)
  • US · Export to Belarus banned: Same HS-based licence requirement
  • US · Export to Iran restricted: check the regime's rules
  • US · Extra due diligence: BIS CHP list; due-diligence guidance
  • US · Re-export safeguards: Reaches certain foreign-produced items too

How they reach the battlefield

Export to Russia is banned — yet the goods still arrive. Official guidance describes this pattern:

  1. 1Made and sold legally

    by a manufacturer in the EU, US, UK, Japan, Switzerland or Asia

  2. 2Bought by a trader

    often unaware of the final destination

  3. 3Re-exported via a third country

    e.g. Armenia, China, Georgia, Hong Kong, India, Israel and 10 more

  4. 4Ends up in Russian weapons

    missiles, drones, helicopters
That is why exporters must check the end user and end use even when the buyer is not in Russia — see the warning signs below.

Is my product dual-use?

The HS code does not decide this. Sanctions name goods by tariff number; dual-use export control lists goods by technical parameters. Every bearing under 8482.10–8482.50 falls under the Russia measures by its HS code; only specialised precision types may fall under Annex I.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 2A001, 2A101[12]. What decides: ISO 492 precision class, ring and rolling-element materials, active magnetic bearing systems and, for 2A101, specific dimensions.

Classification needs the product's technical data sheet; in case of doubt, the export-control authority (SECO, BAFA, ECJU, BIS) can classify it.

Dual-use category 2: Materials processing →Is my product controlled? Five steps →

Before you ship — warning signs

  • Orders from a new trading company with no history in your product line and no clear end user[11]
  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[11]
  • The customer cannot or will not name the end user, the end use or its owners[11]
  • A freight forwarder or logistics company is named as the final end customer or consignee[13]
  • A new customer in, or transit through, a country known as a circumvention hub[14]
  • Deals through intermediaries or shell companies with little economic sense, or a partner sharing its address with many firms[7]

HS codes on the list

HS codeGoodsTierCheck
8482.10Ball bearings3.BCheck →
8482.20Tapered roller bearings3.BCheck →
8482.30Spherical roller bearings3.BCheck →
8482.50Other cylindrical roller bearings3.BCheck →

Tier 1 is the highest priority; tiers 2 to 4 follow in descending order.

What it means for exporters

  • Russia: exports of these goods are prohibited under the EU Russia sanctions (Regulation 833/2014). Switzerland, the UK and the US apply comparable bans. Belarus is under parallel restrictions.
  • Other non-EU countries: EU exporters must contractually prohibit re-export to Russia (“no-Russia clause”, Article 12g) when selling these goods to most countries outside the EU — a short list of partner countries is exempt.
  • Re-export routes: shipments via or to countries named in official guidance as re-export routes deserve particular care with end use and end user: Armenia, China, Georgia, Hong Kong, India, Israel, Kazakhstan, Kyrgyzstan, Macao, Malaysia, Serbia, Thailand, Türkiye, United Arab Emirates, Uzbekistan, Viet Nam.
  • Any destination: depending on their technical parameters, some of these goods are also dual-use items that need an export licence for any destination outside the EU (EU Regulation 2021/821, Annex I; in Switzerland the Goods Control Ordinance). The HS code alone does not decide this — the export-control classification does.

Check a shipment of ball and roller bearings →

Questions

Why is HS 8482.10 restricted for Russia?

Ball bearings are Tier 3 of the Common High Priority list — mechanical components used in Russian weapons systems. The EU, US, UK and Japan list them because Russia keeps importing them for military production, increasingly through third countries.

Is every bearing dual-use?

That depends on parameters. The Russia sanctions cover these HS codes whatever the quality; dual-use control (2A001, 2A101) applies only to specialised precision bearings, defined by ISO 492 precision class, materials, magnetic bearing systems or specific dimensions. The data sheet decides.

Can spare bearings for a customer's existing machines go to a distributor near Russia?

Only after thorough checks: confirm that the machines exist and where they are, check the distributor's history and owners, and obtain end-use statements and a “no-Russia” clause. Unusual volumes or urgency are warning signs; in case of doubt, ask your authority before shipping.

Sources

  1. [1]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 2024).
  2. [2]KSE Institute: Challenges of Export Controls Enforcement: How Russia Continues to Import Components for Its Military Production (Jan 2024).
  3. [3]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  4. [4]Council of the EU: Council Regulation (EU) No 833/2014 (Russia) — Annexes XXIII and XL (consolidated 24 Jul 2026).
  5. [5]Council of the EU: Council Regulation (EC) No 765/2006 (Belarus) — Annex XXX, Arts 1e, 1f, 8g, 8ga (consolidated 24 Apr 2026).
  6. [6]Council of the EU: Council Regulation (EU) 2023/1529 (Iran's military support to Russia) — Annex II (20 Jul 2023).
  7. [7]European Commission: Enhanced due diligence for operators trading with CHP items — Article 12gb, Regulation 833/2014 — FAQ (23 Jul 2025).
  8. [8]Swiss Federal Council: Ordinance on measures in connection with the situation in Ukraine, SR 946.231.176.72 (Art. 5, Art. 14f, Annexes 1 and 31) (status 21 Sep 2026).
  9. [9]SECO: Industrial goods — legal basis and forms (Annexes 1–2 GKV).
  10. [10]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  11. [11]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  12. [12]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).
  13. [13]FinCEN and BIS (US): FIN-2022-Alert003: increased vigilance for potential Russian and Belarusian export control evasion (28 Jun 2022).
  14. [14]European Commission: Guidance for EU operators: implementing enhanced due diligence to shield against Russia sanctions circumvention (2023/2024).

Checked against the sources on 25 Oct 2026. Military uses as documented by the cited reports; Sanctioni names component types, not manufacturers.

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