Exporters Beware: New Russian Sanctions Based On Schedule B and HTS Codes

In the wake of the Russian military’s invasion of Ukraine beginning February 2022, the United States, the European Union and countries around the world are enacting retaliatory sanctions on Russia. This includes new restrictions imposed by the U.S. on exports of items to Russia that could be used in Russian energy and industrial activities.

According to the final rule published by the Bureau of Industry and Security (BIS) in the Federal Register: “These actions reflect the U.S. Government's position that Russia's invasion of Ukraine flagrantly violated international law, was contrary to U.S. national security and foreign policy interests, and undermined global order, peace, and security, all of which necessitated the imposition of stringent and expansive sanctions.”

Whether or not your shipment requires an export license from the U.S. government has until now been primarily determined by the Export Control Numbers (ECNs) of your products, of which there are two types: 

• Export Control Classification Numbers (ECCNs), which are reserved for items considered “dual-use,” meaning they have a commercial use but could be applied in a military or weapons-related use, and which may need a license from the U.S. Department of Commerce depending on the destination country.
• United States Munitions List (USML) Categories, which are reserved for explicitly defense- or space-related items and that always require a license from the U.S. Department of State, regardless of destination country.

The new Russian Industry Sector Sanctions are unique in that they are based on Schedule B codes and Harmonized Tariff Schedule (HTS) codes instead of ECNs. Schedule B and HTS are the general commodity schedules for export from and import into the U.S., respectively. They are based on the global Harmonized System (HS), and are designed to be able to classify every product imaginable.

Effective May 9, 2022, 478 Schedule B codes at the 10-digit level and 205 HTS codes at the six-digit level now require an export license from the U.S. Bureau of Industry and Security (BIS) to export to Russia.

How to Determine If Your Products Need an Export License

How can U.S. exporters keep abreast of so many new restrictions? The Shipping Solutions Export Controls Software has been updated to reflect the new Russian Industry Sector Sanctions. Running a screening is easy:

1. Run Export Screening

Enter the Schedule B number for your product as well as other basic information in the Export Controls Software main screen. In this example, we have entered the Schedule B number 9031.80.8060 - Equipment For Testing Electrical Characteristics Of Internal Combustion Engines. Click the Next button.

2. Review Screening Results

Shipping Solutions returns your results. The top of the screen summarizes the details of the product you entered into the Export Controls Software. The Export Controls Summary clearly indicates if any restrictions apply. In our example, an embargo/sanction may apply, and an export license is definitely required. The bottom of the screen provides more details to help you determine if an embargo or sanction applies to your specific export situation.

3. Reference Export Regulations

The Export Controls Detail section of the screening results explains why in the case of this Schedule B code an export license is required. The Export Control Software will also provide the references you need to confirm your screening results.

Sign Up for a Trial Subscription

Want a closer look at how the Export Controls Software can help your company stay compliant with export regulations? Register now for a free trial subscription of the Shipping Solutions Export Controls Software.

Have questions? Sign up now for a free online demonstration and get your questions answered. In either case, there’s absolutely no obligation!

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