If your company exports goods to Russia or Belarus, you are probably already familiar with EU sanctions. But the European framework is only part of the picture. The United States and the United Kingdom operate their own independent export control regimes — and depending on your products, your supply chain, or the origin of the technology you use, these rules may apply to you even if you are not an American or British company.
This post is not about politics. It is a practical guide for exporters who want to understand what the US and UK sanctions mean for their business, what is still permitted, and where the real obstacles lie in 2026.
Three Systems, One Goal — But Different Rules
The EU, the US and the UK each maintain their own sanctions frameworks. They share the same broad objective — restricting exports that could strengthen Russia’s military and industrial capabilities — but they are legally independent systems with different lists, different thresholds and different enforcement mechanisms.
For European exporters, the most important practical consequence is this: a product that is freely exportable under EU rules may still be restricted under US or UK rules. And conversely, some categories that are tightly controlled by the EU are treated differently across the Atlantic.
The reason US rules can reach beyond American companies is a mechanism known as the Foreign Direct Product Rule (FDP). Under this rule, US export regulations apply to any product — regardless of where it was manufactured — if it was produced using US-origin software, technology or equipment. In practice, this means that a German, Italian or Spanish company manufacturing a product that incorporates American technology may be subject to US export licensing requirements when selling to Russia, even if no American entity is involved in the transaction.
This is not a theoretical concern. Many industrial products — from semiconductors to precision components to software — incorporate US-origin elements somewhere in their production chain. If yours do, checking US rules is not optional.
The US Framework: How It Works in Practice
The legal foundation of US export controls on Russia and Belarus is Section 746.8 of the Export Administration Regulations (EAR), administered by the Bureau of Industry and Security (BIS) of the Department of Commerce.
The core principle is straightforward and strict: a licence is required for the export, re-export or transfer of virtually all items subject to US jurisdiction to Russia or Belarus — and in practice, the vast majority of licence applications are denied. The policy is one of presumption of denial, not case-by-case review.
The restricted items are organised into supplemental lists that cover different product categories:
- Supplement No. 2 covers energy sector equipment — drilling equipment, well completion technology, hydraulic fracturing software and related goods.
- Supplement No. 4 is the broadest list, encompassing more than 500 HS codes across heavy machinery, engine components and industrial chemicals. This is the list most likely to affect general industrial exporters.
- Supplement No. 5 covers luxury goods — high-end clothing, vehicles, jewellery and similar items above certain value thresholds destined for the Russian elite.
- Supplement No. 6 addresses chemicals, biological equipment, laboratory instruments and riot control agents.
- Supplement No. 7 and the broader Common High Priority Items List (CHPL) focus on microelectronics and communications components — the categories most actively monitored because they are frequently found in Russian military systems.
Beyond these lists, specific Russian and Belarusian companies appear on the Entity List, maintained by BIS. Exporting any item subject to EAR to a listed entity requires a licence, which is almost never granted. As of October 2025, both Rosneft and Lukoil have been added to the Specially Designated Nationals (SDN) list — the most restrictive designation — triggering the so-called Affiliates Rule, which extends controls to any subsidiary globally in which these companies hold more than 50% ownership.
The UK Framework: Similar But Not Identical
After leaving the European Union, the United Kingdom built its own sanctions architecture under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). The regime is administered jointly by the Foreign, Commonwealth and Development Office (FCDO) and the Office of Financial Sanctions Implementation (OFSI).
In broad terms, UK export restrictions on goods to Russia mirror those of the EU — and in many cases the lists were developed in close coordination. However, there are important differences, and UK companies cannot simply assume that EU compliance means UK compliance.
Two recent developments are particularly relevant for exporters:
In February 2026, the UK announced a sanctions package targeting logistics companies based in Dubai and Hong Kong — a clear signal that anti-circumvention enforcement is intensifying, not just against direct exports but against third-country routes used to move goods into Russia indirectly.
In March 2026, the UK introduced new end-use controls requiring export licences for goods destined for third countries identified as having a high risk of diversion to Russia. This is a significant expansion: it means that exporting a non-sanctioned product to a country like the UAE or Kazakhstan may now require a licence if there are grounds to suspect onward shipment to Russia.
For exporters using indirect routes — whether intentionally or not — this development substantially increases compliance risk.
What Is Not Sanctioned: Products You Can Still Export
This is the most practically useful part of this post. Despite the breadth of the restrictions, significant categories of goods remain legally exportable to Russia and Belarus under both US and UK rules.
Food and agricultural products are generally permitted. Basic foodstuffs — grains, vegetable oils, processed foods — can be exported without a licence under US rules, provided the recipient is not a sanctioned entity. The humanitarian rationale here is explicit: restrictions are not designed to affect civilian food supply.
Medicines and medical devices are subject to favourable treatment under both regimes. In April 2024, the US introduced the MED licence exception, which explicitly permits the export of EAR99 medical devices, their parts and accessories to civilian end-users in Russia and Belarus without prior authorisation. Conventional pharmaceuticals continue to flow legally, and software required for the operation of diagnostic equipment — X-ray machines, MRI scanners — is exempt from the general software restrictions introduced in 2024.
Everyday consumer goods — provided they do not qualify as luxury items — remain exportable. The distinction between standard consumer goods and luxury goods is primarily based on unit value thresholds:
- Clothing and footwear with a unit value below approximately £300 / €300 are permitted. This covers work clothing, everyday fashion, uniforms and fast-fashion ranges — a significant category that remains open for export.
- Low-end consumer electronics — mobile phones, laptops and headphones — with a unit value below approximately £750 / €750 are generally permitted.
- Personal communication devices and general software updates for the public are allowed under both regimes, on the grounds that cutting off civilian communications access would disproportionately harm ordinary citizens.
- Musical instruments with a unit value below approximately £1,500 / €1,500 can be exported without restriction.
The fashion sector deserves particular attention here. Clothing and footwear represent one of the few product categories where a genuine export opportunity to Russia remains open under all three major sanctions regimes — EU, US and UK — provided the goods fall below the luxury threshold and the buyer is not a sanctioned entity. For companies already holding or considering EAC certification for the Russian market, this is directly relevant: the regulatory pathway for exporting apparel and footwear to Russia remains intact.
If you export or plan to export clothing to Russia and the EAEU, you can find a detailed guide to the certification requirements here: EAC Certification for Clothing.
For footwear exporters, the equivalent guide is here: EAC Certification for Footwear.
The Hidden Obstacle: Payment
Understanding what is legally exportable is only half the problem. For many exporters of permitted goods — food, medicine, clothing — the real barrier is not regulatory: it is financial.
Since 2022, and particularly following US Executive Order 14114 in December 2023, international banks have faced the risk of sanctions if they facilitate transactions that support Russia’s military-industrial base. The difficulty is that banks often cannot verify with certainty where a payment ends up in the chain — and rather than risk a designation, many have adopted blanket de-risking policies, refusing to process payments to Russia even when the underlying export is entirely legal.
The practical consequence is that an exporter of permitted goods — a food company, a clothing manufacturer, a pharmaceutical supplier — may find that their bank simply declines to process the payment, regardless of the product’s legal status. This is not a sanction in the legal sense, but it functions as one.
Before committing to any export order for Russia or Belarus — even for fully permitted goods — verifying that your payment route is viable is an essential first step. A legally compliant product and a willing buyer are not enough if the money cannot move.
The Common High Priority Items List: A Red Flag for Industrial Exporters
One area where US, UK and EU coordination has been particularly tight is the Common High Priority Items List (CHPL) — a shared list of HS codes that all three regimes treat as the highest enforcement priority, because these items are most commonly found in Russian military systems captured on the battlefield.
The key categories include:
- HS 8542 — Electronic integrated circuits, including the most advanced processor and memory chips
- HS 8517 / 8526 — Wireless communications equipment and radar systems
- HS 8504 / 8541 — Diodes, transistors, power converters and electronic components
- HS 8482 — Ball bearings and precision bearings
If your products fall within these categories, the compliance bar is higher than for other goods — not just because the restrictions are stricter, but because enforcement is more active. Customs authorities in multiple countries now specifically screen for these codes in shipments with Russian or Belarusian connections.
What Has Changed in 2025–2026
The sanctions landscape has continued to evolve rapidly, and several recent developments are directly relevant for exporters:
January 2025: OFAC imposed sanctions on banks in Central Asia — particularly in Kyrgyzstan — that had been used as alternative payment corridors for Russia. Several of the most-used financial routes for reaching the Russian market were effectively closed overnight.
October 2025: The US SDN designations of Rosneft and Lukoil triggered the Affiliates Rule, requiring an orderly wind-down of operations under specific licences. Any company that had commercial relationships with subsidiaries of these groups — directly or indirectly — was immediately affected.
February 2026: The UK sanctioned a package of logistics companies operating in Dubai and Hong Kong, targeting the infrastructure used for sanctions circumvention. This signals a shift from restricting the goods themselves to restricting the networks that move them.
March 2026: The UK’s new end-use controls came into force, requiring licences for exports to third countries with identified diversion risk. This is one of the most significant expansions of the UK regime since 2022, and its practical implications for exporters using indirect routes are still being absorbed by the compliance community.
The overall direction is clear: enforcement is becoming more sophisticated, more internationally coordinated, and more focused on closing the routes that have been used to work around direct restrictions.
A Practical Checklist for Exporters
Before proceeding with any export to Russia or Belarus — or to a third country from which goods might be forwarded — work through the following:
- Check all three regimes, not just the EU. If your product contains US-origin technology, the FDP Rule may make US rules applicable regardless of where you are based.
- Search the relevant lists. For the US, check Supplements 2, 4, 5, 6 and 7 of EAR Section 746.8. For the EU, check the consolidated Regulation 833/2014. For the UK, check the current FCDO guidance.
- Screen your buyer. Verify that neither the buyer nor any intermediary appears on the SDN list, the EU asset freeze list or the UK sanctions list. A permitted product shipped to a sanctioned entity is still a violation.
- Check unit value thresholds if you are exporting consumer goods. The difference between a permitted everyday item and a prohibited luxury item can come down to the price per unit.
- Verify your payment route before accepting any order. Confirm that your bank will process the transaction — and if not, explore whether alternative compliant routes exist.
- Check your EAC certification status. If your product is permitted for export, make sure your Russian market certification is current and valid before shipping.
Conclusion
The US and UK sanctions frameworks are independent of — and in some respects stricter than — the EU regime. For any company exporting goods to Russia or Belarus, checking only one of the three systems is not sufficient.
At the same time, the space for legal exports has not disappeared. Food, medicine, and a broad range of everyday consumer goods — including clothing, footwear and low-value electronics — remain open under all three regimes. For companies in these sectors, the practical challenge is less about what is permitted and more about making the permitted transactions actually work: finding compliant payment routes, maintaining up-to-date certifications, and staying ahead of a regulatory environment that continues to evolve quickly.