Goods · EU high-priority items

Exporting semiconductor manufacturing equipment: sanctions risk

Machines for making wafers, semiconductor devices and integrated circuits.

These 3 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

Machines used to make semiconductors: HS 8486.10 (making boules and wafers), 8486.20 (making semiconductor devices and integrated circuits) and 8486.40 (mask and reticle making, assembly and wafer handling) — deposition, etching, lithography, crystal-growing and wafer-handling systems.

Civil uses

  • Chip fabrication for consumer electronics
  • Automotive semiconductor production
  • Solar wafer and cell manufacturing
  • Research and university cleanrooms
  • Smartphone component production

Documented military uses

  • Producing the electronic components found in Russian weapons (why the list includes production equipment)[1]
  • Making substitutes for components recovered from the battlefield[2]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

The list covers not only components found in Russian weapons but also equipment essential for making and testing them. Tier 4 covers manufacturing, production and quality-testing equipment for electronic components, circuit boards and modules. Restricting it limits Russia's ability to make substitute chips at home.[1][3][2]

This group: Tier 4 of 4

  1. Tier 1Chips
  2. Tier 2Radio, navigation, capacitors
  3. Tier 3Other electronics, mechanical and optical parts
  4. Tier 4◀ this groupMachines 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[2]Yes[4]
SwitzerlandCheck[7]Check[8]Check[8]Check[7]Check[7]
United KingdomYes[1]Check[1]Check[1]Yes[1]Check[9]
United StatesYes[10]Yes[10]Check[3]Yes[3]Yes[10]
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. All goods under 8486.10, .20 and .40 are banned for Russia by HS code; separately, only tools meeting 3B001 thresholds are dual-use — older or simpler tools may be outside Annex I but stay sanctioned.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 3B001[11][12]. What decides: process capability — for example lithography light-source wavelength or the smallest feature size, epitaxy uniformity, ion-implant beam energy and current.

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

  • Demand for fab tools, refurbished tools or spare parts from places with no known semiconductor industry[2]
  • A new customer trading in these HS codes, founded after 24 February 2022 and based outside the partner countries[10]
  • The customer cannot or will not name the end user, the end use or its owners[10]
  • 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[2]

HS codes on the list

HS codeGoodsTierCheck
8486.10Machines for the manufacture of boules or wafers4.ACheck →
8486.20Machines for the manufacture of semiconductor devices or integrated circuits4.ACheck →
8486.40Machines specified in note 11(C) to chapter 844.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 semiconductor manufacturing equipment →

Questions

Why is HS 8486.20 restricted for Russia?

These machines make semiconductor devices and integrated circuits. The list includes them in Tier 4 because they are essential for making the electronic components found in Russian weapons systems. The EU prohibits their sale and export to Russia, directly or indirectly, and requires a “no-Russia” clause.

Is all semiconductor manufacturing equipment dual-use?

That depends on parameters. Annex I entry 3B001 lists only equipment meeting specific thresholds, such as advanced lithography or certain epitaxy and ion-implant tools. Equipment below them may be outside the dual-use list but is still banned for Russia by its HS code.

Can we ship spare parts or service a tool installed at a third-country customer?

Carefully. Parts and services can be caught by separate restrictions, and where the tool is installed matters. Verify the location and operator, check the parts' own HS codes and control status, and get advice before providing parts, software or remote support that could benefit Russian users.

Sources

  1. [1]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  2. [2]European Commission: Enhanced due diligence for operators trading with CHP items — Article 12gb, Regulation 833/2014 — FAQ (23 Jul 2025).
  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]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).
  8. [8]SECO: Industrial goods — legal basis and forms (Annexes 1–2 GKV).
  9. [9]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  10. [10]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  11. [11]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).
  12. [12]Export Control Joint Unit (UK): UK Strategic Export Control Lists — consolidated list of strategic military and dual-use items (16 Dec 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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