News & Updates

1 June 2023

Additional Sanctions Against Russia and Belarus

Author: Reynaldo Roman, Sr. Director Regulatory Compliance

The Bureau of Industry and Security (BIS) has implemented additional sanctions against Russia and Belarus under the Export Administration Regulations (EAR). Notably, the agency has added 1,224 new HTS codes to the list of items that require an export license to ship to Russia and Belarus.

The updated list of HTS codes significantly broadens the scope of items now subject to licensing controls under the EAR. Included in the new list of items are chemicals, paper products, packaging and certain medical devices and apparatus.

6-digit HSHS DescriptionProducts typically classified in HS heading
382499Chemical products and preparations of the chemical or allied industries, N.E.S.O.I.; residual products of the chemical or allied industries, N.E.S.O.I.MediCool (Cool-Pack)
MediTray (Cool-Pack)
TIC Series 4/22/M20
(PELICAN) CoolGuard BRIC Panel Series 20M / 22 / 4
901831Syringes, with or without needles; parts and accessories there ofPatient Kits, ancillary supplies
901839Medical etc., needles, catheters, cannulae and the like; parts and accessories there ofPatient Kits, ancillary supplies
901890Instruments and appliances for medical, surgical or veterinary sciences, and parts and accessories there ofPatient Kits, ancillary supplies
902580Hydrometers and similar floating instruments, hygrometers and psychrometersSensitech Temp

BIS has emphasized they will generally review license applications for certain items that are predominantly agricultural or medical in nature on a case-by-case basis, consistent with the pre-existing exceptions to the policy of denial.

Exporters must review their export activities carefully to determine if their export items are subject to the new licensing requirements. Failure to obtain the necessary export licensing can result in fines, penalties, and civil action.

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