Goods · EU high-priority items

Exporting computer processing and other units: sanctions risk

Processing units and other units of automatic data-processing machines (computers).

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

This group covers processing units of computers (HS 8471.50) — servers, industrial PCs and embedded computers — and other computer units (HS 8471.80) such as control and adapter units.

Civil uses

  • Office and data-centre servers
  • Industrial PCs and automation control
  • Medical imaging workstations
  • Telecom network equipment
  • Test and measurement systems
  • Embedded computers in vehicles and machinery

Documented military uses

  • On-board computer of the Kh-101 cruise missile[1]
  • Guidance computers of the Iskander-K missile[2]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

Processing units (8471.50) are Tier 3 of the Common High Priority list — electronic components used in Russian weapons systems; other units (8471.80) are Tier 4 — equipment for making and testing components and modules. Russian missile guidance relies on on-board computers built with Western components.[3][4][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[5]Yes[6]No HS rule[7]Yes[8]Yes[5]
SwitzerlandCheck[9]Check[10]Check[10]Check[9]Check[9]
United KingdomYes[4]Check[4]Check[4]Yes[4]Check[11]
United StatesYes[12]Yes[12]Check[3]Yes[3]Yes[12]
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 unit under 8471.50 and 8471.80 falls under the Russia measures by its HS code; only specialised types — ruggedised, radiation-hardened or encryption-capable computers — may fall under Annex I.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 4A001, 4A003, 5A002[13]. What decides: extended temperature rating, radiation hardening, computing performance and cryptographic functions.

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 4: Computers →Is my product controlled? Five steps →

Before you ship — warning signs

  • Computers or avionics sent abroad “for repair” with invoices that misstate the final destination[12]
  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[12]
  • The customer cannot or will not name the end user, the end use or its owners[12]
  • 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[8]

HS codes on the list

HS codeGoodsTierCheck
8471.50Processing units for automatic data-processing machines3.ACheck →
8471.80Other units of automatic data-processing machines4.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 computer processing and other units →

Questions

Why is HS 8471.50 restricted for Russia?

Processing units are Tier 3 of the Common High Priority list — electronic components used in Russian weapons systems. On-board computers have been documented in Russian missiles. The EU, US, UK and Japan prioritise these codes so that customs and exporters can stop diversion through third countries.

Is every computer processing unit dual-use?

That depends on parameters. The Russia measures cover the HS code whatever the performance; dual-use control applies to computers rated for extreme temperatures or radiation-hardened (4A001), certain high-performance computers (4A003) or items with controlled cryptography (5A002). Check the specification against Annex I.

Can I sell standard servers to a reseller in a third country?

Possibly, but only with due diligence: confirm the end user and end use, include the contractual “no-Russia” clause where your rules require it (EU Art. 12g) and screen all parties. Volumes that do not fit the reseller's business are a warning sign; in case of doubt, ask your export-control authority.

Sources

  1. [1]Defence Intelligence of Ukraine (GUR): Components in the aggressor's weapons (War & Sanctions).
  2. [2]RUSI: Silicon Lifeline: Western Electronics at the Heart of Russia's War Machine (8 Aug 2022).
  3. [3]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 2024).
  4. [4]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  5. [5]Council of the EU: Council Regulation (EU) No 833/2014 (Russia) — Annexes XXIII and XL (consolidated 24 Jul 2026).
  6. [6]Council of the EU: Council Regulation (EC) No 765/2006 (Belarus) — Annex XXX, Arts 1e, 1f, 8g, 8ga (consolidated 24 Apr 2026).
  7. [7]Council of the EU: Council Regulation (EU) 2023/1529 (Iran's military support to Russia) — Annex II (20 Jul 2023).
  8. [8]European Commission: Enhanced due diligence for operators trading with CHP items — Article 12gb, Regulation 833/2014 — FAQ (23 Jul 2025).
  9. [9]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).
  10. [10]SECO: Industrial goods — legal basis and forms (Annexes 1–2 GKV).
  11. [11]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  12. [12]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  13. [13]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).
  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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