Goods · EU high-priority items

Exporting integrated circuits (chips): sanctions risk

Processors, microcontrollers, memory, amplifier and other chips — Tier 1, the components most often found in Russian weapons.

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

Integrated circuits (chips) are complete electronic circuits on a small piece of silicon. They do the processing, storage and signal handling inside almost every electronic device: HS 8542.31 covers processors and controllers such as microcontrollers, 8542.32 memories, 8542.33 amplifiers, 8542.39 other ICs such as FPGAs.

Civil uses

  • Engine, braking and airbag control units in cars
  • Smartphones, routers and other communication devices
  • Laptops, servers and data storage
  • Medical devices such as patient monitors and imaging systems
  • Factory automation, robots and machine controllers
  • Household appliances, smart meters and solar inverters

Documented military uses

  • Microcontrollers and FPGAs in cruise missiles (Kalibr, Kh-101)[1]
  • Integrated circuits in Orlan-10 reconnaissance drones[1]
  • Microcontrollers in Filin cruise missiles[2]
  • Non-Russian electronics in the on-board computers of Kh-101 missiles and Ka-52 helicopters[3]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

Integrated circuits are Tier 1 of the Common High Priority list — the tier of highest concern. They are critical to Russian precision-guided weapons, Russia makes few of them itself, and only a small number of companies worldwide produce them. The EU, the US, the UK and Japan drew up the list from components recovered on the battlefield in Ukraine. It helps exporters focus their due diligence and customs authorities target circumvention through third countries.[4][5][1]

This group: Tier 1 of 4 — the highest priority

  1. Tier 1◀ this groupChips
  2. Tier 2Radio, 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]Check[8]Yes[9]Yes[6]
SwitzerlandCheck[10]Check[11]Check[11]Check[10]Check[10]
United KingdomYes[12]Check[12]Check[12]Yes[12]Check[13]
United StatesYes[1]Yes[1]Yes[1]Yes[5]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: Listed drone-relevant types (FPGA, MCU, MPU, MMIC amplifiers)
  • 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: Same HS-based licence requirement
  • US · Extra due diligence: BIS CHPL Tier 1; 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 chip under 8542.31–.39 falls under the Russia measures, whatever its specifications; dual-use licensing is a separate question decided part by part (in the US: by ECCN).

Products in this group may fall under the EU dual-use list, Annex I, entries such as 3A001, 3A101, 3A501, 5A002[14][15]. What decides: radiation hardening, rated operating temperature, ADC/DAC resolution and sample rate, FPGA input/output count and transceiver data rate, processing performance, 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 3: Electronics →Is my product controlled? Five steps →

Before you ship — warning signs

  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[1]
  • An existing customer orders these goods for the first time, or sharply more, since February 2022[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[16]
  • A new customer in, or transit through, a country known as a circumvention hub[17]
  • 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
8542.31Integrated circuits: processors and controllers1Check →
8542.32Integrated circuits: memories1Check →
8542.33Integrated circuits: amplifiers1Check →
8542.39Integrated circuits: other1Check →

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 integrated circuits (chips) →

Questions

Why is HS 8542.31 restricted for Russia?

Processors and controllers such as microcontrollers are Tier 1 Common High Priority items: chips under this code have been recovered from Russian weapons used in Ukraine, including Kalibr and Kh-101 cruise missiles and Orlan-10 drones. The EU lists them in Annex XL of Regulation 833/2014, whose export to Russia — directly or indirectly — is banned; the US requires a licence.

Is every integrated circuit dual-use?

That depends on technical parameters, not on the HS code. A chip may fall under 3A001 or related entries depending on radiation hardening, temperature rating, converter or FPGA performance, processing performance or cryptography — each part has to be classified on its own. The Russia sanctions apply to all of HS 8542.31–.39 regardless of that result.

Can I export chips to Kazakhstan or Türkiye?

There is no general answer. Both are named in official guidance as transit points for goods reaching Russia. EU exporters need an enforceable “no-Russia” re-export clause (Art. 12g) and documented, risk-based due diligence (Art. 12gb): check the end user, the end use and the warning signs. Dual-use licences may apply depending on the chip, and US-origin parts carry their own re-export rules.

Sources

  1. [1]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  2. [2]Defence Intelligence of Ukraine (GUR): Components in the aggressor's weapons (War & Sanctions).
  3. [3]Conflict Armament Research: Component commonalities in advanced Russian weapon systems (Sep 2022).
  4. [4]European Commission: List of Common High Priority Items (version of February 2024) (22 Feb 2024).
  5. [5]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 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]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  13. [13]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  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]Bureau of Industry and Security (US): Classify your item (ECCN, Commerce Control List, EAR99).
  16. [16]FinCEN and BIS (US): FIN-2022-Alert003: increased vigilance for potential Russian and Belarusian export control evasion (28 Jun 2022).
  17. [17]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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