Article by: Glenn Shearron, Trade Compliance Specialist, ECoP

There is usually no connection between the Harmonized Tariff Schedule (HTS) Code and the Export Administration Regulations (EAR). However, the Commerce Department’s Bureau of Industry and Security (BIS) does connect certain HS codes to the EAR regarding Russia and Belarus.

The export controls on Russia and Belarus have strengthened by adding 94 6-digit HTS codes to the list of items that require a license for export, reexport, or transfer in-country to Russia or Belarus. The expanded list includes items such as lubricants, certain chemicals, metals, and includes the entire chapter 88 of the HTS, which will include aircraft, spacecraft, and parts thereof. There is also expansion of controls on certain EAR99 items regarding antennas, antenna reflectors, and parts thereof.

The Federal Register notice can be found here.

The previous press release from BIS can be found here.

You should also familiarize yourself with 15 CFR parts 744 and 746, including the supplements, as well as the sanctions programs and country information of the Office of Foreign Assets Control (OFAC), which can be found here.

As always, for any exports destined for Russia, Belarus, or the surrounding countries, denied party screening of all parties to the transaction is a must.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website for updates on this and other topics.