Introduction
During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)“), with seven new Harmonized System (“HS“) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can expect that the items on the Lists will be an enforcement priority in these jurisdictions.
Listed products include electronic components, such as integrated circuits and radio frequency transceiver modules, and items that are essential for the manufacturing and testing of the electronic components and circuits. Companies that sell and ship the Listed products should be on high alert for possible red flags indicating that the items could be diverted to Russia.
Updated Lists
Seven new HS codes have been added to the Lists, including bearings needed for heavy vehicles or other machinery and antennae used for navigation systems. Additionally, Tier 3 has been subdivided into Tier 3A (other electrical components) and Tier 3B (mechanical components). Subsequently, the Lists are now divided into four tiers ranked according to their relative degree of criticality. Tier 1 (integrated circuits) and Tier 2 (electronic components) contain particularly sensitive items of the highest concern for Russian weapons systems. Tier 3 is divided between electrical (Tier 3A) and mechanical (Tier 3B) components, and Tier 4 pertains to manufacturing, production and quality testing equipment.
On 19 September 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS“) announced an updated List following meetings with key members of the Global Export Control Coalition (see here).
On 14 September 2023, the UK’s Foreign, Commonwealth & Development Office (“FCDO“) added these seven new HS product codes to the List (see here).
In September 2023, the EU released an updated version of its List of High Priority Battlefield Items (see here).
Japan’s existing list of products that are subject to an export ban to Russia can be found at pages 7 to 20 here.
