Guides to EU sanctions

The CN code (Combined Nomenclature) is the 8-digit customs code of a product, the same one you use in the customs declaration and on the export invoice. You will find it in your customs documentation, in the TARIC system or from your customs agency. You enter it in Restrikt to check the sanctions status of the item.

No match only means that the given CN code was not found in our database of regimes, not that the trade is permitted. Check a higher level of the CN code, the other regime and, separately, the list of persons and entities under sanctions. The binding text is the EU regulation, not the tool result.

These are two separate EU legal acts with their own goods annexes. Regulation 833/2014 covers Russia and Regulation 765/2006 covers Belarus, and the same CN code may be banned under one regime and absent from the other. That is why you check the item separately for each destination, and Restrikt shows the result with the legal basis specific to the given regime.

EU goods regimes: Russia (833/2014); Belarus (765/2006); North Korea (2017/1509); Iran (267/2012); Iran (military support to Russia, 2023/1529); Crimea and Sevastopol (692/2014); Donetsk, Luhansk, Zaporizhzhia and Kherson oblasts (2022/263). With each result you see the legal basis, that is the annex and article, as well as the date of the consolidated version, with a link to the full text in EUR-Lex.

The No Russia clause is a requirement under art. 12g of Regulation 833/2014 to contractually prohibit the re-export of certain sensitive goods to Russia in sales to third countries. It applies to EU exporters selling, among others, dual-use goods and items from selected annexes. In practice you place the relevant contractual clause in the contract and on the invoice, and its absence may be treated as a failure of due diligence.

Article 3k of Regulation 833/2014 bans the export of a broad list of industrial goods set out in Annex XXIII. At the same time it provides exemptions and derogations, that is situations where trade remains permitted, for example performing contracts concluded before the ban took effect. Exemptions are attached to the article, not to the individual CN code, so Restrikt shows the exemptions in the article covering your code and points to the relevant paragraph on EUR-Lex. Whether it applies to a specific transaction is confirmed by the customs authority or a law firm.

No. CBAM is the EU carbon charge on imports of carbon-intensive goods such as steel, aluminium, cement or fertilisers. The importer reports the emissions and covers them with CBAM certificates. Sanctions are trade bans and restrictions under Regulations 833/2014 and 765/2006. These are two different legal regimes, so the same product may be subject to CBAM and at the same time not be covered by sanctions, or the other way round.

Keep a record of the check for every item: the CN code, sanctions status, regime, annex and article, the version date of the regulation and the EUR-Lex link. Add screening of the counterparty against sanctions lists and, where art. 12g requires it, the No Russia clause in the contract. Restrikt prepares a report with this data, to print or save as PDF, that you attach to the transaction file as proof of due diligence in case of a customs inspection.

From the consolidated texts of EU regulations published in EUR-Lex and from the TARIC nomenclature. For each code we show the date of the version of the act on which the result is based, and a direct link to the source, so you can verify the wording in the original.

Restrikt checks the goods, that is whether a given CN code is subject to an import or export restriction. Sanctions screening is a separate process that verifies the counterparty, that is a person or entity, against sanctions lists. Both steps are needed, the tool does not replace counterparty screening.

SENT is Poland’s system for reporting the transport of certain goods. Whether a shipment must be notified depends on the CN code, quantity, route and type of transaction, not on the code alone. The consignor (SENT100), the consignee (SENT200) or, for transport through Poland, the carrier (SENT300) files the notification before the transport starts. Failing to notify exposes the consignor or consignee to a penalty of 46% of the gross value of the goods, not less than 20,000 PLN (Article 21(1) of the Act).

ADR is the European agreement on the international carriage of dangerous goods by road. Each dangerous substance has a four-digit UN number, which indicates its hazard class. The packing group, warning labels, hazard identification number (Kemler) and tunnel restriction code are given by the entry for that number in Table A. Some UN numbers have several entries, for example with different packing groups. The right entry then depends on the properties of the goods, e.g. as shown in the safety data sheet. On the ADR page you will find a UN number search, the list of classes and three tools: load compatibility, the 1000-point limit and limited quantities (LQ).

No. Restrikt is an informational tool supporting due diligence, it does not constitute legal or customs advice. The final assessment of the compliance of a specific transaction is confirmed by a law firm or customs agency. The binding text is the EU regulation in force, for example 833/2014.