Goods · EU high-priority items

Exporting capacitors: sanctions risk

Tantalum and multilayer ceramic capacitors — passive components used on almost every circuit board.

These 2 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

Passive components that store and release electrical charge — they filter, stabilise and decouple power on nearly every circuit board. The list covers tantalum capacitors (HS 8532.21) and multilayer ceramic capacitors, MLCCs (HS 8532.24).

Civil uses

  • Smartphones and laptops
  • Automotive electronics and electric-vehicle power systems
  • Medical implants and devices
  • Industrial control boards
  • Power supplies and inverters
  • Household appliances

Documented military uses

  • Among the HS codes found in Kalibr and Kh-101 cruise missiles[1]
  • Among the HS codes found in the Orlan-10 reconnaissance drone[1]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

Capacitors sit on every circuit board in missiles and drones, and these HS codes were found in Russian weapons recovered in Ukraine. Both are Tier 2 — Russia may have some domestic production but prefers to source from the US and its allies. The EU bans their export to Russia and requires a contractual “no-Russia” clause.[2][3][1]

This group: Tier 2 of 4

  1. Tier 1Chips
  2. Tier 2◀ this groupRadio, navigation, capacitors
  3. Tier 3Other 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[10]Check[10]Check[10]Yes[10]Check[11]
United StatesYes[1]Yes[1]Yes[1]Yes[3]Yes[1]
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: BIS licence required for Iran
  • 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. Only specialised types such as high-energy pulse or high-voltage low-inductance capacitors may fall under 3A001.e.2 or 3A201.a; the Russia ban applies to all of HS 8532.21 and 8532.24 whatever their parameters.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 3A001.e.2, 3A201.a[12][13]. What decides: voltage rating, stored energy and energy density, capacitance, series inductance and repetition rate.

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 3: Electronics →Is my product controlled? Five steps →

Before you ship — warning signs

  • A customer outside the coalition countries that never bought tantalum capacitors or MLCCs before February 2022, or whose orders jumped afterwards[1]
  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[1]
  • The customer cannot or will not name the end user, the end use or its owners[1]
  • A freight forwarder or logistics company is named as the final end customer or consignee[14]
  • A new customer in, or transit through, a country known as a circumvention hub[15]
  • 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
8532.21Tantalum capacitors2Check →
8532.24Multilayer ceramic capacitors2Check →

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 capacitors →

Questions

Why is HS 8532.24 restricted for Russia?

Multilayer ceramic capacitors are among the nine HS codes the US authorities found in Russian weapons such as Kalibr and Kh-101 missiles and the Orlan-10 drone. They are a Tier 2 Common High Priority item; the EU bans their export to Russia and expects enhanced due diligence on re-export risk.

Is every capacitor dual-use?

That depends on parameters: only specialised types such as high-energy storage or pulse capacitors may fall under Annex I 3A001.e.2 or 3A201.a — voltage, energy, capacitance, inductance and repetition rate decide. Ordinary MLCCs and tantalum parts are usually below the thresholds but remain banned for Russia by HS code.

We sell capacitors through distributors. How do we manage re-export risk?

Put the “no-Russia” clause in distributor contracts, watch for unusual volume increases and new customers in transit hubs, ask for end-user information on large or unusual orders and screen all parties. Document your checks — high-priority items carry enhanced due-diligence expectations.

Sources

  1. [1]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  2. [2]European Commission: List of Common High Priority Items (version of February 2024) (22 Feb 2024).
  3. [3]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 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]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  11. [11]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  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]Export Control Joint Unit (UK): UK Strategic Export Control Lists — consolidated list of strategic military and dual-use items (16 Dec 2025).
  14. [14]FinCEN and BIS (US): FIN-2022-Alert003: increased vigilance for potential Russian and Belarusian export control evasion (28 Jun 2022).
  15. [15]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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