Goods · EU high-priority items

Exporting wireless and communication modules: sanctions risk

Modules and apparatus that receive, convert or transmit voice, images or data — for example radio, Wi-Fi, cellular and transceiver modules.

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

Modules and apparatus that send, receive, convert or route voice, images or data — wireless transceiver modules, routers and switches — under HS 8517.62 (machines for reception, conversion and transmission of data) and 8517.69 (other transmission and reception apparatus).

Civil uses

  • Wi-Fi, Bluetooth and cellular modules in consumer devices
  • Network routers and switches
  • Industrial machine-to-machine telemetry
  • Connected-car telematics
  • Smart-home devices and meters
  • Remote patient monitoring

Documented military uses

  • Software-defined radio inside Shahed-136 attack drones used in Ukraine[1]
  • Goods under HS 8517.62, such as transceiver modules, found in Kalibr and Kh-101 cruise missiles[2]
  • The same codes found in the Orlan-10 reconnaissance drone[2]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

The EU, US, UK and Japan identified these goods in Russian weapons recovered in Ukraine. HS 8517.62 is Tier 2 — electronics Russia may partly make itself but prefers to source from the West; HS 8517.69 is Tier 3 — further electronic components with a broader range of suppliers. Both are banned for export to Russia under the EU Russia regulation.[3][4][5][6]

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[6]Yes[7]No HS rule[8]Yes[9]Yes[6]
SwitzerlandCheck[10]Check[11]Check[11]Check[10]Check[10]
United KingdomYes[5]Check[5]Check[5]Yes[5]Check[12]
United StatesYes[2]Yes[2]Yes[13]Yes[4]Yes[2]
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. The HS code decides the Russia ban; the same 8517.62 module may or may not be dual-use — check its encryption and telecom specification.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 5A001, 5A002[14][15][16]. What decides: hardening against radiation or electromagnetic pulse, operation at extreme temperatures, other telecom features of Category 5 Part 1, and cryptography for data confidentiality (Category 5 Part 2).

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 5: Telecommunications and information security →Is my product controlled? Five steps →

Before you ship — warning signs

  • Order volumes that do not fit the customer's stated line of business[2]
  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[2]
  • The customer cannot or will not name the end user, the end use or its owners[2]
  • A freight forwarder or logistics company is named as the final end customer or consignee[17]
  • A new customer in, or transit through, a country known as a circumvention hub[18]
  • Deals through intermediaries or shell companies with little economic sense, or a partner sharing its address with many firms[9]

HS codes on the list

HS codeGoodsTierCheck
8517.62Machines for reception, conversion and transmission of voice, images or data2Check →
8517.69Other apparatus for transmission or reception of voice, images or data3.ACheck →

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 wireless and communication modules →

Questions

Why is HS 8517.62 restricted for Russia?

Goods under this code, such as wireless transceiver modules, were found in Russian weapons recovered in Ukraine, including cruise missiles and drones. It is a Tier 2 Common High Priority item; the EU bans its export to Russia and EU exporters must contractually prohibit re-export to Russia.

Is every wireless module dual-use?

That depends on technical parameters, not on the HS code: only specialised types fall under Annex I 5A001 or 5A002 — for example modules hardened for extreme environments or using controlled cryptography. Classify each part against its data sheet; the Russia ban on HS 8517.62 applies whatever the result.

A distributor in a third country orders large volumes of Wi-Fi/LTE modules. What should I check?

Ask for end-use and end-user details, check when the buyer was founded, its web presence and whether volumes fit its business. Include the “no-Russia” clause and screen all parties. A sudden rise in orders since 2022 is a recognised warning sign; in case of doubt, ask your export-control authority.

Sources

  1. [1]Conflict Armament Research: Dissecting Iranian drones employed by Russia in Ukraine (Nov 2022).
  2. [2]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  3. [3]European Commission: List of Common High Priority Items (version of February 2024) (22 Feb 2024).
  4. [4]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 2024).
  5. [5]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  6. [6]Council of the EU: Council Regulation (EU) No 833/2014 (Russia) — Annexes XXIII and XL (consolidated 24 Jul 2026).
  7. [7]Council of the EU: Council Regulation (EC) No 765/2006 (Belarus) — Annex XXX, Arts 1e, 1f, 8g, 8ga (consolidated 24 Apr 2026).
  8. [8]Council of the EU: Council Regulation (EU) 2023/1529 (Iran's military support to Russia) — Annex II (20 Jul 2023).
  9. [9]European Commission: Enhanced due diligence for operators trading with CHP items — Article 12gb, Regulation 833/2014 — FAQ (23 Jul 2025).
  10. [10]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).
  11. [11]SECO: Industrial goods — legal basis and forms (Annexes 1–2 GKV).
  12. [12]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  13. [13]US Department of Commerce, BIS (eCFR): EAR Part 746, Supplement No. 7 — items requiring a licence for Russia, Belarus, Iran and Crimea (by HS code).
  14. [14]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).
  15. [15]Export Control Joint Unit (UK): UK Strategic Export Control Lists — consolidated list of strategic military and dual-use items (16 Dec 2025).
  16. [16]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
  17. [17]FinCEN and BIS (US): FIN-2022-Alert003: increased vigilance for potential Russian and Belarusian export control evasion (28 Jun 2022).
  18. [18]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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