The Bureau of Industry and Security (BIS) has released a new best practice guidance identifying forty-five Harmonized System (HS) codes covered under controlled items. Of those nine HS codes have been prioritized as the most impactful to Russian weapon requirements.

Prioritized HS codes:

  1. 8542.31
  2. 8542.32
  3. 8542.33
  4. 8542.39
  5. 8517.62
  6. 8526.91
  7. 8532.21
  8. 8532.24
  9. 8548.00

BIS strongly recommends—although not required by law—that companies begin using customer certifications or end-user statements, if they are not doing so already, for shipments with items that include certain electronic integrated circuits, radars, capacitors, and other items listed on the first page of the guidance as a safeguard to help prevent diversion of controlled items to Russia.

While numerous U.S. companies already require customers to sign end-user statements, the agency advises those companies to still review the guidance for examples of what information they should have documented to comply.

If you have questions on end-user statement certifications, reach out to Mohawk Global Trade Advisors.

By Clarissa Chiclana

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