How to check whether sanctions apply to your goods
Restrictions are based not on the name of the goods but on the HS code (Harmonised System code). The same product described in different words may or may not fall under a restriction list — the code decides.
On the EU to Central Asia route there are three separate layers to consider. First, EU export restrictions set out in Regulation 765/2006 as amended (2022/355), whose Annexes VI-XIV list specific groups: tobacco industry goods, mineral products, fertilisers, wood, cement, iron and steel, tyres, and part of the machinery in chapters 84-85.
Second, the national counter-restriction registries of Belarus and Russia. These are independent lists that change separately from EU legislation and carry their own validity periods. For transit they matter even when the goods are not restricted in the EU.
Third, dual-use items. Here the HS code is only a hint: certain chapters (28, 29, 38, 71, 84, 85, 88, 89, 90, 93) frequently contain positions requiring a separate licence. The final answer depends on the technical characteristics of the goods, not the code.
This is why an automated check is the first step, not the last. It quickly shows whether a code appears in known lists, but customs decides on the basis of the actual goods description, origin and destination. If the code is reclassified at the border, the conclusion changes with it.
A practical tip: check the code before signing the contract, not once the cargo is loaded. A mismatch spotted in time is usually resolved with documentation or a change of route; spotted at the border, it costs standstill time.