Goods · EU high-priority items

Exporting test and measurement instruments: sanctions risk

Signal generators, oscilloscopes, multimeters and other instruments for measuring electrical quantities, optical instruments, and equipment for testing wafers and semiconductor devices.

These 6 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

Electronic and optical measuring instruments: signal generators (HS 8543.20), instruments using optical radiation (9027.50), oscilloscopes (9030.20), recording multimeters and meters (9030.32, 9030.39) and instruments for testing wafers and devices (9030.82) — used to design, test and check electronics.

Civil uses

  • Electronics development and repair
  • Telecom and radio network testing
  • Semiconductor wafer testing
  • Power-grid and electrical maintenance
  • Laboratory spectroscopy and analysis
  • Automotive electronics diagnostics

Documented military uses

  • Testing the electronic components and circuits used in Russian weapons (why the list includes test equipment)[1]
  • Sophisticated test equipment sought for military use through procurement schemes[2]
Military uses only as documented by the sources cited — the same component, two very different end uses.

Why they are restricted

Equipment for making and quality-testing electronic components, circuit boards and modules is Tier 4 of the list. Without oscilloscopes, signal generators and device testers, Russian producers cannot develop or verify the electronics used in weapons systems.[1][3][4]

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[5]Yes[6]Check[7]Yes[4]Yes[5]
SwitzerlandCheck[8]Check[9]Check[9]Check[8]Check[8]
United KingdomYes[1]Check[1]Check[1]Yes[1]Check[10]
United StatesYes[2]Yes[2]Check[3]Yes[3]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: Thermal sensors for drone cameras listed
  • 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 listed HS codes are banned for Russia by code; only high-performance types may be dual-use — most bench instruments are below the thresholds but stay sanctioned.

Products in this group may fall under the EU dual-use list, Annex I, entries such as 3A002, 3B002[11][12]. What decides: for oscilloscopes, bandwidth and noise; for signal analysers and generators, frequency range, resolution bandwidth and noise; for semiconductor testers, frequency capability.

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

  • High-end test instruments ordered through intermediaries who will not name the end user or end use[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[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[4]

HS codes on the list

HS codeGoodsTierCheck
8543.20Signal generators4.ACheck →
9027.50Instruments using optical radiation (UV, visible, IR)4.ACheck →
9030.20Oscilloscopes and oscillographs4.ACheck →
9030.32Multimeters with recording device4.ACheck →
9030.39Instruments for measuring voltage, current, resistance or power, with recording device4.ACheck →
9030.82Instruments for measuring or checking semiconductor wafers or devices4.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 test and measurement instruments →

Questions

Why is HS 9030.20 restricted for Russia?

Oscilloscopes are Tier 4 of the Common High Priority list — equipment for making and quality-testing the electronic components and circuit boards found in Russian weapons. The EU prohibits selling, supplying or exporting them to Russia, directly or indirectly, and requires a contractual ban on re-export to Russia.

Is every oscilloscope or signal generator dual-use?

That depends on parameters: Annex I entry 3A002 lists only instruments beyond specific thresholds, such as very high-bandwidth, low-noise oscilloscopes or analysers and generators with certain frequency specifications. Ordinary bench instruments are usually below them — the Russia ban still applies by HS code.

A distributor asks for many handheld multimeters with recording function. Any concern?

Recording multimeters (HS 9030.32, 9030.39) are high-priority items even when simple. Check that quantities fit the distributor's market, confirm the end users and include a “no-Russia” clause. Unexplained order surges or routing via known transit hubs call for enhanced due diligence.

Sources

  1. [1]FCDO (UK): Russia sanctions — Common High Priority Items List (8 Aug 2024).
  2. [2]FinCEN and BIS (US): FIN-2023-Alert004: supplemental alert on Russian export control evasion (19 May 2023).
  3. [3]Bureau of Industry and Security (US): Common High Priority Items List (CHPL) (23 Feb 2024).
  4. [4]European Commission: Enhanced due diligence for operators trading with CHP items — Article 12gb, Regulation 833/2014 — FAQ (23 Jul 2025).
  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]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]UK Government: Russia sanctions: statutory guidance (20 May 2026).
  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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