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.

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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