US Adds to List of High-Priority Exports to Monitor for Russia-Related Diversion

The U.S. and three of its partners this week expanded the list of common high-priority items that exporters and others should closely monitor for potential diversion to Russia. The list includes seven new Harmonized System codes -- among them for bearings used for heavy vehicles and antennae used for navigation systems -- and was rearranged to provide “greater clarity” to exporters conducting due diligence on shipments.

The updates, which BIS said the U.K., the EU and Japan also made, target products that “are more significant to Russian weaponry than others,” and come after the agency in May issued an alert of several “high priority items” to monitor along with their HS codes (see 2305190059 and 2308150051). A BIS official recently said the agency is “doing an all-out push” to make sure industry, including forwarders, are aware of the risks associated with shipping items that fall under those HS codes.

Among the new items are certain ball bearings that may be used in heavy machinery and “antennas and antenna reflectors of all kinds.” The list now includes 45 items that pose a “heightened risk of being diverted illegally to Russia because of their importance to Russia’s war efforts,” and BIS said it divided Tier 3 of the list into mechanical and nonmechanical items to “provide greater clarity.”

The agency said the nine HS codes in Tiers 1 and 2 are “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,” BIS said.

Since the start of Russia’s war against Ukraine, BIS said, exports to Russia from the U.S. and its allies that are part of the Global Export Control Coalition have decreased by 52.3%, or by $81.1 billion, which has led to “numerous challenges for the Russian defense industrial base.” The agency specifically pointed to “the bankruptcy of Russia’s most advanced semiconductor producer, ongoing struggles with supplies to repair, replace, and replenish a variety of military equipment, and efforts to acquire weapons and other support from pariah states like Iran and North Korea.”

BIS added that, along with its coalition partners, the U.S. will continue to coordinate with other countries on their export restrictions. It also said it will update the HS code list periodically.