BIS: Allies release updated list of priority items

The Department of Commerce’s Bureau of Industry and Security (BIS) released updates to its list of controlled “common high priority” items identified as critical to Russia’s war effort following meetings with key members of the Global Export Control Coalition.

Since the onset of Russia’s further invasion of Ukraine in February 2022, the United States and its international allies and partners have implemented a series of export controls that restrict Russia’s access to the items it needs to sustain the war. While BIS’s controls cover a vast array of items necessary to fuel Russia’s war machine, certain items are more significant to Russian weaponry than others.

As part of this effort and in coordination with our partners in the United Kingdom, the European Union and Japan, in July 2023 BIS published a list of 38 high priority items that Russia seeks to procure for its weapons programs. The list is divided into four tiers, ranked according to their relative degree of criticality.

In coordination with partners, BIS has added seven new Harmonized System (HS) codes to the list, including bearings needed for heavy vehicles or other machinery and antennae used for navigation systems.

Additionally, Tier 3 has been divided into mechanical and non- mechanical items to provide greater clarity.

As published in our previous guidance involving the nine HS codes in Tiers 1 and 2 of highest priority, exporters and reexporters are strongly encouraged to conduct due diligence when encountering the listed HS codes to identify possible third-party intermediaries and attempts at evasion of U.S. export controls.

Russia Export Controls – List of Common High-Priority Items

Since February 24, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) has implemented a series of stringent export controls  that restrict Russia’s access to the technologies and other items that it needs to sustain its brutal attack on Ukraine. These restrictions also apply to Belarus in response to its substantial enabling of Russia’s destabilizing conduct.

While BIS’s controls cover a vast array of items necessary to fuel Russia’s war machine, certain items are more significant to Russian weaponry than others. Working with theUnited Kingdom and European Union, BIS has identified 45 “common high-priority items” by six-digit Harmonized System (HS) Codes that Russia seeks to procure for its weapons programs. In this notice, BIS is publicizing these 45 common high-priority items to highlight for industry that these items pose a heightened risk of being diverted illegally to Russia because of their importance to Russia’s war efforts. The list may be updated periodically as new information becomes available.

List of Common High Priority Items

The list is divided into four tiers.

• Tier 1: Items of the highest concern due to their critical role in the production of advanced Russian precision-guided weapons systems, Russia’s lack of domestic production, and limited global manufacturers.
• Tier 2: Additional electronics items for which Russia may have some domestic production capability but a preference to source from the United States and its partners and allies.
• Tier 3.A: Further electronic components used in Russian weapons systems, with a broader range of suppliers.
• Tier 3.B: Mechanical and other components utilized in Russian weapons systems.
• Tier 4: Manufacturing, production and quality testing equipment for electric components, circuit boards and modules.

Within this list, BIS has prioritized the nine HS codes in Tier 1 and Tier 2—covering items such as integrated circuits and radio frequency (RF) transceiver modules—that have extensive commercial applications but have also been found in Russian missiles and drones on the battlefield in Ukraine.