Short answer: dual-use goods are civilian goods, software and technology whose characteristics may bring them within export-control rules. Screening does not begin with a generic product name and does not end with a TN VED code: the technical parameters must be compared against all six current Russian control lists. Depending on the transaction, an identification opinion, a licence from Russia’s Federal Service for Technical and Export Control (FSTEC) or authorisation from the Export Control Commission may be required. These are different documents. Certain categories are controlled not only when exported from Russia but also when imported into Russia.
Published · Updated
Reference guide to Russian export controls
In brief: these are civilian products whose properties also allow them to be used in sensitive fields. The controlled item may be a physical product, software, technology, technical information, work, a service or a result of intellectual activity.
Federal Law No. 183-FZ uses the broader term “controlled goods and technologies”. The specific categories are set out in control lists covering equipment, materials, substances, microorganisms, software and technology. A generic commercial description such as “machine tool”, “sensor”, “pump” or “software” is therefore not enough to determine the control status.
The status is determined by considering the characteristics together, including:
A civilian end use does not automatically remove a product from control. Conversely, a product name resembling a listed entry does not by itself mean that the particular model is controlled: every mandatory criterion must be checked.
In brief: these are separate legal regimes governed by different rules, authorities and documents. One product may fall under more than one regime, so holding a document under one regime does not remove the need to check the others.
| Regime | What is checked | Main document | Practical conclusion |
|---|---|---|---|
| Export control | Whether the product matches a control-list entry and whether catch-all control applies | Identification opinion, FSTEC licence or Commission authorisation, depending on the transaction | The code and technical characteristics must be checked together |
| Military products | Whether the product was specially designed for military use and qualifies as military products | Documents required under military-technical cooperation legislation | The dual-use regime does not replace this regime |
| Encryption products | Presence and purpose of cryptographic functions | Licence, authorisation or registered notification details, according to the applicable procedure | A notification does not confirm that export control is inapplicable |
| Other products in the EAEU Common List | Applicable foreign-trade prohibitions and restrictions | A licence, opinion or other document required by the relevant section | Checked separately from Federal Law No. 183-FZ |
The screening of cryptographic functions is explained in “Authorisation documents for imports into Russia”. The general method for identifying the required document is covered in “How to determine which document is required”.
In brief: as of 6 October 2026, six principal control lists apply. Five were approved by Russian Government Resolutions Nos. 1284–1288 of 16 July 2022, and the sixth by Resolution No. 1299 of 19 July 2022.
| Control list | Legal act | What it covers |
|---|---|---|
| Chemical | Resolution No. 1284 of 16 July 2022 | Chemicals, equipment, software and technology associated with chemical weapons |
| Nuclear | Resolution No. 1285 of 16 July 2022 | Nuclear materials, equipment, special non-nuclear materials and technology |
| Nuclear-related dual-use | Resolution No. 1286 of 16 July 2022 | Industrial, measuring and other equipment, materials and technology |
| Biological | Resolution No. 1287 of 16 July 2022 | Microorganisms, toxins, equipment, software and technology |
| Missile | Resolution No. 1288 of 16 July 2022 | Equipment, materials, software and technology for missile systems |
| General dual-use list | Resolution No. 1299 of 19 July 2022 | Materials, electronics, computers, telecommunications, sensors, navigation, marine and aerospace systems and other categories |
Some reference pages still cite the former presidential decrees. Operational screening should use the government resolutions and their current versions.
A TN VED code in a list helps identify a possible entry, but it does not replace comparison of the product description and parameters. The role of the code is explained in “What depends on the TN VED code”.
Even if a product is absent from all six lists, the analysis may not be complete. Article 20 of Federal Law No. 183-FZ establishes catch-all control. An unlisted product may require authorisation from the Export Control Commission where the grounds specified in that article concerning end-use risk apply, or where the participant receives written notice from the competent authority. The conditions in Article 20 and the authorisation procedure must be checked, not merely whether the product appears in a list.
In brief: FSTEC of Russia is the specially authorised federal body for export control; the Export Control Commission decides cases covered by catch-all control; and customs authorities verify compliance with prohibitions and restrictions when goods are moved across the border.
| Authority or party | Role | Outcome or document |
|---|---|---|
| Government of the Russian Federation | Approves the control lists and control procedures | Resolutions and rules |
| FSTEC of Russia | Licences transactions, maintains the prescribed registers, exercises control and provides public services | Licence, Russian Import Certificate and decisions within its competence |
| Export Control Commission of the Russian Federation | Considers transactions subject to catch-all control | Commission authorisation |
| Customs authorities | Verify declared information and the availability of required documents during customs procedures | Release, request for documents or another customs-control decision |
| Foreign-trade participant | Identifies the product, supplies accurate information and complies with the terms of authorisations | Technical dossier, identification opinion and transaction documents |
A customs representative can handle customs formalities but cannot replace the manufacturer’s information about the product’s composition, functions and parameters. Before a customs declaration is lodged, the owner of the goods must provide a sufficiently detailed technical description.
In brief: most of the regime concerns the transfer of controlled products to foreign persons and their export from Russia, but the statement that “export control only covers exports” is incorrect. Russian law permits the licensing of imports of certain controlled products, and the current list under Resolution No. 1299 contains a separate section for goods whose import is controlled for national-security reasons.
| Transaction | What must be checked | Possible document |
|---|---|---|
| Import into Russia | Whether the product appears in the import section of a list or under another prohibition or restriction | FSTEC licence or another document, but only where required by the particular entry and legal act |
| Export from Russia | Control list, technical characteristics, consignee and end use | FSTEC licence or another prescribed mechanism |
| Transfer of technology to a foreign person | Content and means of transfer, rights to the technology and recipient | Licence, if the transaction is licensable |
| Temporary export | Purpose, no transfer to a foreign person, return and retention of control | Without a licence only if the conditions of the applicable act are met; otherwise an authorisation document is required |
| Re-export or onward transfer of imported products | Terms of the original supply and end-use assurances | Consent or authorisation where required by the documents and regime |
| Transit | Type of product, route, procedure and special restrictions | Must be assessed separately before dispatch |
An import licence should not be confused with a Russian Import Certificate. The certificate is issued to a Russian importer when the competent authority in the exporting country requires confirmation of the stated end use. It does not replace a Russian licence and is not automatically required for every import contract.
When goods move between EAEU member states, the absence of ordinary customs declaration at an internal border does not cancel national export-control rules. Export-control requirements must therefore be checked separately even for transactions within the Union. See our EAEU guide for the distinction between the internal market and customs procedures.
In brief: first assemble a complete technical dossier, then check all six control lists and every applicable note. Searching only by TN VED code or model name is not sufficient.
Screening procedure:
The key principle of Resolution No. 565 is that identification must enable a clear comparison between the specific product and the control lists. A short description from an invoice is not sufficient.
If the supplier’s documents contradict one another, the analysis should stop until the discrepancy is resolved. A convenient specification from a marketing page cannot be selected while the product passport or actual configuration is ignored.
A working sheet for collecting information, not a product identification assessment report.
| Item/model | Function | Relevant parameter | Unit | Manufacturer's document | Unknown information |
|---|---|---|---|---|---|
| Complete | Describe intended use | Enter documented value | Specify unit | Title and section | State the question |
Mark unknown parameters as unknown rather than selecting values by analogy. This sheet does not itself determine whether a licence is needed and does not replace an assessment.
We can help assemble the technical dossier, determine the applicable procedure and arrange an identification assessment → export control and authorisation documents.
In brief: identification determines whether a specific product or technology matches an entry in a control list. An independent identification assessment is one way to obtain a substantiated opinion; it does not replace a licence.
Identification may be carried out by the Russian foreign-trade participant itself or by an expert organisation authorised to conduct independent identification assessments under the prescribed procedure. The result is documented in the prescribed form of identification opinion.
| Question | Identification opinion | FSTEC licence |
|---|---|---|
| What does it answer? | Does the product match a specific entry in a control list? | Is the applicant permitted to carry out the specified foreign-trade transaction? |
| Basis | Technical characteristics and control lists | Identification opinion, transaction documents, recipient, end use and other information |
| Who prepares or issues it? | Foreign-trade participant or authorised expert organisation | FSTEC of Russia |
| Does it replace the other document? | No | No |
Customs does not have to request an independent opinion for every shipment. It may, however, verify compliance with prohibitions and restrictions and request documents supporting the declared information. An opinion is therefore particularly important when a code or description resembles a controlled entry, specifications are close to a threshold, or the manufacturer’s documents are ambiguous.
The rules do not establish a universal formula under which every opinion remains valid for a fixed number of years. Before reusing one, check whether the model, configuration, characteristics, control list, country, recipient or transaction has changed.
In brief: if a product is included in a control list and the transaction is licensable, the licence is issued by FSTEC of Russia. If the product is not listed but catch-all control applies, authorisation from the Export Control Commission is required.
| Document | Prepared or issued by | When it applies | Validity |
|---|---|---|---|
| Identification opinion | Foreign-trade participant or expert organisation | To record the product’s control status | No universal term; it must remain applicable to the unchanged product and transaction |
| Individual licence | FSTEC of Russia | For a specific transaction, product, quantity and recipient | Specified in the licence |
| General licence | FSTEC of Russia in cases prescribed by law | For permitted product categories and destinations, subject to special conditions | Specified in the licence |
| Commission authorisation | Export Control Commission of the Russian Federation | For a transaction under Article 20 of Federal Law No. 183-FZ where the product is not listed | Specified in the authorisation |
| End-user undertaking | Foreign recipient or another party under the applicable procedure | Confirms the stated use and restrictions on onward transfer | Applies to the specific transaction |
| Russian Import Certificate | FSTEC of Russia or its regional office | When required by the competent authority of the exporting country | Applies to the specific import shipment |
Practical export sequence:
A temporary export without transfer to a foreign person may proceed without a licence only if the statutory conditions and the applicable regulation are met, including continued direct control by the Russian participant and return within the prescribed period. This is not an automatic exemption for every exhibition or repair shipment.
A substantive review requires product functions and technical parameters supported by the manufacturer's documents. Assistance with Russian FSTEC licences and product identification assessment starts with this information and a description of the transaction.
In brief: administrative or criminal liability may apply. The type of liability depends on the transaction, whether a document was mandatory, the accuracy of the information supplied, intent and other circumstances. A delayed shipment alone does not determine that an offence has occurred.
| Violation | Possible liability | Provision |
|---|---|---|
| Transaction without a mandatory licence or authorisation, breach of its conditions, unlawful acquisition of a document or false information | Administrative | Article 14.20 of the Russian Code of Administrative Offences |
| Breach of transaction-recording rules or document-retention period | Administrative | Part 2 of Article 14.20 of the Russian Code of Administrative Offences |
| Failure to comply with customs prohibitions and restrictions, or false declaration | Administrative, depending on the facts | Applicable articles of Chapter 16 of the Russian Code of Administrative Offences |
| Knowingly unlawful export or transfer to a foreign person of controlled goods, technology, work or services | Criminal, where all elements of the offence are present | Article 189 of the Russian Criminal Code |
Senateks’ practical recommendation is to document a disputed product status before signing the contract and dispatching the goods. If customs has already made a decision, the next steps depend on the document and the stage of the inspection — see legal support in customs disputes.
Code and authorisation-document errors are covered separately: consequences of an incorrect code and when an authorisation document must be ready.
In brief: an importer needs complete specifications, a commodity code and the import documents; an exporter additionally needs product identification, recipient screening and the correct authorisation mechanism. The checks should be completed before payment and dispatch.
Before an import contract:
Before an export or transfer of technology:
Once the documents have been checked, we can prepare the declaration for import, export or transit → customs operations.
Parallel imports do not override export controls. Russia's mechanism for importing certain genuine goods without the right holder's consent does not remove the exporting country's prohibitions, licensing requirements, or end-user and end-use restrictions. A brand or product entry appearing in Russia's list does not establish that a foreign supplier may export the goods. Review brand-related rights separately from controlled specifications, transaction parties and intended use. See parallel imports: conditions and limitations.
As of 6 October 2026:
Assemble a technical dossier and compare the specifications against every applicable control list. If the conclusion is ambiguous or affects the transaction, prepare an identification opinion or arrange an independent assessment.
Not for every product. Import licensing applies to particular categories. List No. 1299 contains a dedicated import section, so the specific entry and current version of the list must be checked.
No. A code is not the sole criterion in every list, and Article 20 of Federal Law No. 183-FZ also controls unlisted products where the statutory conditions are met.
Identification may be performed by the foreign-trade participant or an authorised expert organisation. There is no universal validity term: before reuse, check that the product, list and transaction remain unchanged.
Yes. The control lists contain separate entries for software and technology. Their functions, parameters and the notes to the list matter, not the method of delivery.
The destination country’s EAEU membership does not by itself cancel Russian export control. The required document depends on the product, transaction and applicable regulation.
Sometimes, provided that the Russian participant retains direct control, the product is not transferred to a foreign person and its return is mandatory. The conditions must be checked before dispatch; the word “temporary” does not itself create an exemption.
Only if the product is also covered by the rules for encryption products. Cryptographic notification and export control are separate regimes; the notification screening procedure is explained in the separate reference guide.
Depending on the circumstances, Article 14.20 of the Russian Code of Administrative Offences or Article 189 of the Russian Criminal Code may apply, as may relevant customs offences. Classification depends on the documents and facts of the particular transaction.
It is a document for a Russian importer confirming the stated use of controlled products when required by the competent authority in the exporting country. It is not a universal import licence.
In brief: laws and resolutions should be checked on Russia’s official legal-information portal, current public services and registers on the FSTEC website, and customs rules on EAEU and Federal Customs Service resources. A saved copy of a control list that has not been checked for amendments is not suitable for a live transaction.
Some footnotes below link to the ConsultantPlus and Garant legal-reference databases rather than official publications. For a specific transaction, check the cited text against the current legal instrument and the effective dates of amendments.
| What must be checked | Source | What to look for |
|---|---|---|
| Laws and resolutions | pravo.gov.ru, government.ru | Current version and effective date of amendments |
| Six control lists | Official publications of Resolutions Nos. 1284–1288 and 1299 | Entry, code, parameters, notes and exclusions |
| Identification | Resolution No. 565 and the FSTEC website | Form of opinion and authorised expert organisations |
| Licensing | Resolution No. 691 and the FSTEC website | Type of licence, application and transaction documents |
| Catch-all control | Article 20 of Federal Law No. 183-FZ and Resolution No. 517 | Grounds for Commission authorisation |
| Customs formalities | EAEU Customs Code and Federal Customs Service | Prohibitions, restrictions and data required in the declaration |
| Encryption products | EEC Board Decision No. 30 and the FSB Licensing, Certification and State Secret Protection Centre | Licence, authorisation or notification details under the separate regime |
| Liability | Russian Code of Administrative Offences and Criminal Code | Version of the relevant article in force on the transaction date |
Before relying on a rule, locate the legal act by number, open its current version, check the effective date of amendments and compare it with the transaction date.
Ask us about a specific shipment → contact Senateks LLC.
This material is provided for general information and does not constitute legal advice. It does not describe methods of circumventing export controls.
Federal Law No. 183-FZ of 18 July 1999 on Export Control, in particular Articles 6, 7, 18–20 and 24 — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102060254 (accessed 6 October 2026).
Russian Government Resolutions Nos. 1284–1288 of 16 July 2022; official publications Nos. 0001202207190026, 0001202207190029, 0001202207190018, 0001202207190030 and 0001202207190036 — https://publication.pravo.gov.ru/documents/block/government?index=564 (accessed 6 October 2026).
Russian Government Resolution No. 1299 of 19 July 2022 approving the list of dual-use goods and technologies, version incorporating the 2026 amendments — https://www.consultant.ru/document/cons_doc_LAW_422722/ (accessed 6 October 2026).
Decision No. 30 of the Board of the Eurasian Economic Commission of 21 April 2015 on non-tariff regulatory measures, including Annex 9 on encryption products — https://docs.eaeunion.org/documents/292/1553/ (accessed 6 October 2026). Public text of Annex 9 on the FSB Licensing, Certification and State Secret Protection Centre website — https://clsz.fsb.ru/files/download/reshenie_N_30_prilogenie_N_9.pdf (licensing and notification-registration provisions rechecked using the indexed text on 8 October 2026).
Federal Law No. 114-FZ of 19 July 1998 on Military-Technical Cooperation of the Russian Federation with Foreign States — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102054195 (accessed 6 October 2026).
Russian Government Resolution No. 517 of 15 August 2005 on obtaining authorisation from the Export Control Commission of the Russian Federation, version of 5 August 2022 — https://www.consultant.ru/document/cons_doc_LAW_55148/ (accessed 6 October 2026).
Presidential Decree No. 1085 of 16 August 2004 on the Federal Service for Technical and Export Control — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102088202 (accessed 6 October 2026).
Treaty on the Customs Code of the Eurasian Economic Union, provisions concerning prohibitions, restrictions and customs formalities — https://docs.eaeunion.org/documents/236/2895/ (accessed 6 October 2026).
Russian Government Resolution No. 317 of 25 March 2026 amending Government Resolution No. 1299 of 19 July 2022 — https://government.ru/docs/all/128587/ (accessed 6 October 2026).
Resolution No. 1030 of the Council of Ministers — Government of the Russian Federation of 11 October 1993 on assurances concerning the use of imported and exported dual-use goods — https://base.garant.ru/5139739/ (accessed 6 October 2026).
Russian Government Resolution No. 565 of 21 June 2016 on the procedure for identifying controlled goods and technologies, the form of the identification opinion and rules for completing it — https://publication.pravo.gov.ru/Document/View/0001201606240013 (accessed 6 October 2026).
Russian Government Resolution No. 691 of 15 September 2008 approving the regulations on licensing foreign-trade transactions, version of 15 July 2024 — https://www.consultant.ru/document/cons_doc_LAW_80105/ (accessed 6 October 2026).
Article 14.20 of the Russian Code of Administrative Offences, “Violation of export-control legislation”, version in force on 6 October 2026 — https://www.consultant.ru/document/cons_doc_LAW_34661/6e4bbb2e7d47a361acb2f28bc5f84819dfc9c266/ (accessed 6 October 2026).
Article 189 of the Russian Criminal Code, “Unlawful export from the Russian Federation or transfer of goods or technologies…”, version in force on 6 October 2026 — https://www.consultant.ru/document/cons_doc_LAW_10699/0742784fa77198de3bace7c8b2656e9e7cac471f/ (accessed 6 October 2026).
Federal Customs Service of Russia, register of customs representatives: Senateks LLC, certificate No. 2123 — https://customs.gov.ru/registers/customs-representatives (accessed 6 October 2026).