Configuring Classification for Items Subject to Sanctions

Sanctions establishing restrictions on the import or export of certain items identify these items in different ways. The Council Regulations imposing EU sanctions against Belarus and Iran, for example, define specific nomenclatures for some of the controlled items. The same regulations additionally refer to the HS and to the CN to designate other items affected by the sanctions. Some regulations only provide a narrative description of the items subject to their control regimes.

If dual-use items are also subject to sanctions, the latter usually takes precedence over the national or supranational export control legislation. Often, the export of dual-use items to sanctioned countries is prohibited.

The implementation of sanctions on items and activities subject to the EAR is based on the CCL including "basket" code EAR99. Except for a few items like food and medicine, a license is required to export or reexport any item subject to the EAR to one of the sanctioned countries mentioned in Part 746.

Numbering schemes and numbering scheme contents for dedicated nomenclatures defined in legislation imposing sanctions against persons or countries are always customer-specific additions to delivery Customizing. They have to be created using the numbering scheme type 002 Export Control Classification Numbers (ECCN, AL).

If the legislation only provides a narrative description of the items subject to sanctions, the codes to be used in classification for legal control are freely definable.

The commodity code of a product cannot be used in classification for legal control. If the items subject to sanctions are identified by the HS chapter or heading under which they are classified for customs and statistical purposes, the relevant chapters or headings could be mapped as control classes in a customer-specific numbering scheme content.