How to check an HS code for sanctions: step by step for transit via Belarus and Russia
Step 1. Take the code from the invoice
The first 6 digits of the HS code are the same in the EU, the EAEU and Uzbekistan. If the supplier gave an 8- or 10-digit code, use all of it: bans often apply to a narrower subheading rather than the whole heading. If there is no code, find it from the description in LITAR.
Step 2. Separate a transit ban from an export ban
This is the key distinction. A transit ban through Belarus applies to codes in Annexes XIX, XIVa and Va to Regulation (EC) 765/2006, and through Russia to codes in Annexes VII, XI, XX and XXXVII to Regulation (EU) 833/2014. Such goods cannot travel through these countries even if they are legal in the EU and at destination.
An export ban to Russia or Belarus (Annex XXIII to 833/2014, Annexes XVIII and XIV to 765/2006) does not close transit to Central Asia, but customs check the final destination more strictly: you will need the contract with the consignee in Uzbekistan or Kazakhstan and an end-user declaration.
Step 3. Check the Russian and Belarusian counter-lists
Besides EU sanctions, Russia (including Government Resolution No. 1292) and Belarus (Council of Ministers Resolutions No. 240 and No. 808) apply their own restrictions. They change independently of EU law and matter for transit even when the goods are not restricted in the EU.
Step 4. Assess dual use
Here the HS code is only a hint: chapters 28, 29, 38, 71, 84, 85, 88, 89, 90 and 93 often contain items that need a licence. The final answer depends on the technical characteristics of the goods, not the code.
Step 5. Veterinary and phytosanitary control
Goods of animal and plant origin fall under EAEU lists (Customs Union Commission Decisions No. 317 and No. 318). Veterinary and phytosanitary certificates are issued in Lithuania before dispatch.
Step 6. Confirm with an official source
For the final decision use LITAR (measures in force today), the consolidated texts of Regulations 765/2006 and 833/2014 on EUR-Lex, and Access2Markets. Our free HS code check runs steps 2–5 at once: it shows which list the code was found in and links to LITAR.
What to do if a code is restricted
A match does not always mean a ban: it means a measure applies that has to be assessed together with the route and the consignee. If only Belarus is closed, the route via Latvia and Russia remains; if transit through Russia is closed too – the Caspian route via Turkey, Georgia, Baku and Aktau (18–28 days) or air.
When to check
Before signing the contract, not when the cargo is already loaded. A mismatch caught in time is usually solved with documents or another route; caught at the border, it means downtime. In groupage one shipper’s wrong code stops the whole truck, so we check codes before consolidation.
Questions and answers
How do I check an HS code for sanctions?
Take the code from the invoice, separate a transit ban from an export ban, check the Russian and Belarusian counter-lists, assess dual use, check veterinary and phytosanitary control, and confirm with an official source (LITAR, EUR-Lex). Our free HS code check runs the main steps at once.
What is the difference between a transit ban and an export ban?
A transit ban means goods cannot travel through Belarus or Russia even if they are legal in the EU and at destination. An export ban to Russia or Belarus does not close transit to Central Asia, but customs check the final destination more strictly and require the contract with the consignee and an end-user declaration.
Sources: Regulation (EC) 765/2006 and Regulation (EU) 833/2014 (consolidated texts on EUR-Lex), LITAR – Lithuanian Customs integrated tariff. This article is general information, not legal advice.
Related: How to ship cargo to Uzbekistan or Kazakhstan: 7 steps