Dual-use goods: what they are, how to screen your product and what is required for import and export

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.

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  • Senateks

Reference guide to Russian export controls

Contents#

  1. What are dual-use goods?
  2. How do they differ from military products and encryption products?
  3. Which control lists apply in Russia?
  4. Who regulates dual-use goods?
  5. Does the regime cover imports or only exports?
  6. How do you screen a specific product?
  7. What is an identification assessment?
  8. What is required for export from Russia?
  9. What liability may apply?
  10. What should be checked before signing a contract?
  11. Key terms
  12. Frequently asked questions
  13. Official sources

What are dual-use goods in plain language?#

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:

  • purpose and design;
  • technical parameters and thresholds;
  • materials and composition;
  • software functions;
  • notes, definitions and exclusions within the relevant list;
  • where specified, the EAEU TN VED commodity code.

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.

How do dual-use goods differ from military products and encryption products?#

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.

RegimeWhat is checkedMain documentPractical conclusion
Export controlWhether the product matches a control-list entry and whether catch-all control appliesIdentification opinion, FSTEC licence or Commission authorisation, depending on the transactionThe code and technical characteristics must be checked together
Military productsWhether the product was specially designed for military use and qualifies as military productsDocuments required under military-technical cooperation legislationThe dual-use regime does not replace this regime
Encryption productsPresence and purpose of cryptographic functionsLicence, authorisation or registered notification details, according to the applicable procedureA notification does not confirm that export control is inapplicable
Other products in the EAEU Common ListApplicable foreign-trade prohibitions and restrictionsA licence, opinion or other document required by the relevant sectionChecked 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”.

Which dual-use control lists apply in Russia?#

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 listLegal actWhat it covers
ChemicalResolution No. 1284 of 16 July 2022Chemicals, equipment, software and technology associated with chemical weapons
NuclearResolution No. 1285 of 16 July 2022Nuclear materials, equipment, special non-nuclear materials and technology
Nuclear-related dual-useResolution No. 1286 of 16 July 2022Industrial, measuring and other equipment, materials and technology
BiologicalResolution No. 1287 of 16 July 2022Microorganisms, toxins, equipment, software and technology
MissileResolution No. 1288 of 16 July 2022Equipment, materials, software and technology for missile systems
General dual-use listResolution No. 1299 of 19 July 2022Materials, 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.

Who regulates dual-use goods in Russia?#

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 partyRoleOutcome or document
Government of the Russian FederationApproves the control lists and control proceduresResolutions and rules
FSTEC of RussiaLicences transactions, maintains the prescribed registers, exercises control and provides public servicesLicence, Russian Import Certificate and decisions within its competence
Export Control Commission of the Russian FederationConsiders transactions subject to catch-all controlCommission authorisation
Customs authoritiesVerify declared information and the availability of required documents during customs proceduresRelease, request for documents or another customs-control decision
Foreign-trade participantIdentifies the product, supplies accurate information and complies with the terms of authorisationsTechnical 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.

Does Russian export control cover imports into Russia or only exports?#

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.

TransactionWhat must be checkedPossible document
Import into RussiaWhether the product appears in the import section of a list or under another prohibition or restrictionFSTEC licence or another document, but only where required by the particular entry and legal act
Export from RussiaControl list, technical characteristics, consignee and end useFSTEC licence or another prescribed mechanism
Transfer of technology to a foreign personContent and means of transfer, rights to the technology and recipientLicence, if the transaction is licensable
Temporary exportPurpose, no transfer to a foreign person, return and retention of controlWithout 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 productsTerms of the original supply and end-use assurancesConsent or authorisation where required by the documents and regime
TransitType of product, route, procedure and special restrictionsMust 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.

How do you determine whether a specific product is dual-use?#

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:

  1. Record the manufacturer, model, part number, configuration, country of origin and intended transaction.
  2. Collect the product passport, datasheet, manual, drawings, composition data, photographs of markings and software description.
  3. Determine the likely EAEU TN VED code and identify which documents depend on it — see the procedure for determining the code.
  4. Search all potentially applicable lists by description, code and technical characteristics.
  5. Compare every mandatory criterion: ranges, accuracy, performance, material, operating temperature, functions, purpose and exclusions.
  6. Assess software, technology and technical information separately from the physical equipment.
  7. Screen the recipient, end use and the conditions for catch-all control.
  8. Record the conclusion in an identification opinion; arrange an independent identification assessment for complex or disputed products.

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.

Technical dossier template

A working sheet for collecting information, not a product identification assessment report.

Item/modelFunctionRelevant parameterUnitManufacturer's documentUnknown information
CompleteDescribe intended useEnter documented valueSpecify unitTitle and sectionState 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.

What is an identification assessment and when is it needed?#

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.

QuestionIdentification opinionFSTEC 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?
BasisTechnical characteristics and control listsIdentification opinion, transaction documents, recipient, end use and other information
Who prepares or issues it?Foreign-trade participant or authorised expert organisationFSTEC of Russia
Does it replace the other document?NoNo

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.

What is required to export dual-use goods from Russia?#

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.

DocumentPrepared or issued byWhen it appliesValidity
Identification opinionForeign-trade participant or expert organisationTo record the product’s control statusNo universal term; it must remain applicable to the unchanged product and transaction
Individual licenceFSTEC of RussiaFor a specific transaction, product, quantity and recipientSpecified in the licence
General licenceFSTEC of Russia in cases prescribed by lawFor permitted product categories and destinations, subject to special conditionsSpecified in the licence
Commission authorisationExport Control Commission of the Russian FederationFor a transaction under Article 20 of Federal Law No. 183-FZ where the product is not listedSpecified in the authorisation
End-user undertakingForeign recipient or another party under the applicable procedureConfirms the stated use and restrictions on onward transferApplies to the specific transaction
Russian Import CertificateFSTEC of Russia or its regional officeWhen required by the competent authority of the exporting countryApplies to the specific import shipment

Practical export sequence:

  1. define the product and transaction;
  2. carry out identification;
  3. assess catch-all control and screen the recipient;
  4. agree the end-use documents with the foreign party;
  5. determine the required type of licence or authorisation;
  6. obtain the document before the transaction takes place;
  7. declare its details to customs and comply with every condition;
  8. retain the technical documents, opinion, authorisation and transaction records.

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.

What liability applies to export-control violations?#

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.

ViolationPossible liabilityProvision
Transaction without a mandatory licence or authorisation, breach of its conditions, unlawful acquisition of a document or false informationAdministrativeArticle 14.20 of the Russian Code of Administrative Offences
Breach of transaction-recording rules or document-retention periodAdministrativePart 2 of Article 14.20 of the Russian Code of Administrative Offences
Failure to comply with customs prohibitions and restrictions, or false declarationAdministrative, depending on the factsApplicable 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 servicesCriminal, where all elements of the offence are presentArticle 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.

What should be checked before signing a contract with a foreign supplier or exporting from Russia?#

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:

  • obtain the product passport, datasheet, manual and software description;
  • agree the exact model and configuration across all documents;
  • determine the TN VED code;
  • check authorisation documents by code and product;
  • check cryptographic functions separately;
  • check the import section of the control lists;
  • establish whether the exporting country will require a Russian Import Certificate or end-use document;
  • make the supplier’s duty to provide technical documents an express contractual term.

Before an export or transfer of technology:

  • check all six control lists;
  • prepare an identification opinion;
  • assess catch-all control and screen the recipient and end use;
  • determine whether an FSTEC licence or Commission authorisation is required;
  • obtain the foreign recipient’s undertakings;
  • check any other export restrictions in force;
  • align the authorisation document with the customs declaration;
  • retain the screening and transaction records.

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.

Export-control terms#

As of 6 October 2026:

  • Export control — a set of measures regulating foreign-trade transactions involving controlled products.
  • Controlled goods and technologies — goods and technologies subject to export control under Russian law.
  • Catch-all control — control of transactions involving unlisted products under the conditions of Article 20 of Federal Law No. 183-FZ.
  • Identification — comparison of a specific product against control-list entries under the rules of Resolution No. 565.
  • Independent identification assessment — identification performed by an organisation authorised to conduct such assessments.
  • Identification opinion — the prescribed document recording the result of identification.
  • Individual licence — a licence for a specific foreign-trade transaction on the terms stated in it.
  • General licence — a licence for categories of transactions prescribed by law without naming a specific foreign recipient.
  • Russian Import Certificate — a government assurance that imported controlled products will be used for the stated purposes.
  • Internal export-control programme — organisational measures adopted by a foreign-trade participant to comply with export-control requirements.
  • EAEU TN VED code — the commodity-classification code used for customs purposes; it helps identify a possible entry but does not replace technical identification.
  • Customs representative — a person entered in the Federal Customs Service register that performs customs formalities on behalf of the declarant. Senateks LLC is registered under certificate No. 2123.

Frequently asked questions about dual-use goods#

How do I determine whether my product is dual-use?

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.

Do I need an FSTEC licence to import dual-use goods into Russia?

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.

If the TN VED code is absent from a list, does that prove the product is not controlled?

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.

Who conducts an identification assessment, and how long is an opinion valid?

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.

Can software be subject to export control?

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.

Is a licence required for a shipment to Kazakhstan or Belarus?

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.

Can equipment be temporarily exported for an exhibition or repair without a licence?

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.

Does a dual-use product require an FSB cryptographic notification?

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.

What are the consequences of exporting without a mandatory licence?

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.

What is a Russian Import Certificate?

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.

Where can Russian export-control rules be checked?#

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 checkedSourceWhat to look for
Laws and resolutionspravo.gov.ru, government.ruCurrent version and effective date of amendments
Six control listsOfficial publications of Resolutions Nos. 1284–1288 and 1299Entry, code, parameters, notes and exclusions
IdentificationResolution No. 565 and the FSTEC websiteForm of opinion and authorised expert organisations
LicensingResolution No. 691 and the FSTEC websiteType of licence, application and transaction documents
Catch-all controlArticle 20 of Federal Law No. 183-FZ and Resolution No. 517Grounds for Commission authorisation
Customs formalitiesEAEU Customs Code and Federal Customs ServiceProhibitions, restrictions and data required in the declaration
Encryption productsEEC Board Decision No. 30 and the FSB Licensing, Certification and State Secret Protection CentreLicence, authorisation or notification details under the separate regime
LiabilityRussian Code of Administrative Offences and Criminal CodeVersion 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.

Notes

15
  1. 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).

  2. 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).

  3. 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).

  4. 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).

  5. 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).

  6. 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).

  7. 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).

  8. 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).

  9. 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).

  10. 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).

  11. 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).

  12. 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).

  13. 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).

  14. 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).

  15. 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).

Sources

  1. Federal Law No. 183-FZ of 18 July 1999 on Export Control
  2. Russian Government Resolutions Nos. 1284–1288 of 16 July 2022
  3. Russian Government Resolution No. 1299 of 19 July 2022
  4. Russian Government Resolution No. 317 of 25 March 2026
  5. Russian Government Resolution No. 565 of 21 June 2016
  6. Russian Government Resolution No. 691 of 15 September 2008
  7. Russian Government Resolution No. 517 of 15 August 2005
  8. Resolution No. 1030 of the Council of Ministers — Government of the Russian Federation of 11 October 1993
  9. Presidential Decree No. 1085 of 16 August 2004 on the Federal Service for Technical and Export Control
  10. Treaty on the Customs Code of the Eurasian Economic Union
  11. Decision No. 30 of the EEC Board of 21 April 2015
  12. Federal Law No. 114-FZ of 19 July 1998 on Military-Technical Cooperation
  13. Article 14.20 of the Russian Code of Administrative Offences
  14. Article 189 of the Russian Criminal Code
  15. Federal Customs Service of Russia — register of customs representatives