Art. 12gb • due diligence
Common high priority items and the due diligence obligation
Annex XL to Regulation 833/2014 lists the goods that most often reach Russia by a detour. Being on that list is not a ban, it is the switch that turns on the obligations of Article 12gb. Our database holds 50 entries from Annex XL and 2 from Annex XLVIII, against the consolidated text of 24 July 2026.
Four steps an inspection expects
- Check whether the code is on the CHP list. Take the CN code and check whether it appears in Annex XL (common high priority items) or Annex XLVIII to Regulation 833/2014.
- Assess the risk of export to Russia. Article 12gb requires a risk assessment proportionate to the size of the company: who the customer is, where the goods actually go, whether the route or the counterparty points to circumvention.
- Put the No Russia clause in the contract. When selling to a third country, the contractual ban on re-export to Russia (Art. 12g) is mandatory for sensitive goods.
- Document the check with a date. An inspection does not ask whether you knew, but whether you can show what you checked and when. A dated record with the version of the act is the proof of due diligence.
Annex XL, the CN code list
Click a code to see the full sanctions status, article and exemptions.
- 8457 10 Machining centres
- 8458 11 Horizontal lathes, numerically controlled
- 8458 91 Other lathes, numerically controlled
- 8459 61 Other milling machines, numerically controlled
- 8466 93 Parts and accessories for machines of headings 8456 to 8461
- 8471 50 Processing units other than those of subheadings 8471 41 or 8471 49, whether or not contai
- 8471 80 Other units of automatic data-processing machines
- 8482 10 Ball bearings
- 8482 20 Tapered roller bearings, including cone and tapered roller assemblies
- 8482 30 Spherical roller bearings
- 8482 50 Other cylindrical roller bearings, including cage and roller assemblies
- 8486 10 Machines and apparatus for the manufacture of boules or wafers
- 8486 20 Machines and apparatus for the manufacture of semiconductor devices or of electronic integ
- 8486 40 Machines and apparatus specified in note 11 (C) to this chapter
- 8504 40 Static converters
- 8517 62 Machines for the reception, conversion and transmission or regeneration of voice, images o
- 8517 69 Other apparatus for the transmission or reception of voice, images or other data
- 8525 89 Other television cameras, digital cameras and video camera recorders
- 8526 91 Radio navigational aid apparatus
- 8529 10 Aerials and aerial reflectors of all kinds; parts suitable for use therewith
- 8529 90 Other parts suitable for use solely or principally with the apparatus of headings 8524 to
- 8532 21 Other fixed capacitors, tantalum
- 8532 24 Other fixed capacitors, ceramic, multilayer
- 8534 00 Printed circuits
- 8536 69 Other plugs and sockets
- 8536 90 Other apparatus of heading 8536
- 8541 10 Diodes, other than photosensitive or light-emitting diodes (LED)
- 8541 21 Transistors, other than photosensitive transistors, with a dissipation rate of less than 1
- 8541 29 Transistors, other than photosensitive transistors, other
- 8541 30 Thyristors, diacs and triacs, other than photosensitive devices
- 8541 49 Other photosensitive semiconductor devices
- 8541 51 Other semiconductor devices: Semiconductor-based transducers
- 8541 59 Other semiconductor devices: Other
- 8541 60 Mounted piezoelectric crystals
- 8542 31 Processors and controllers, whether or not combined with memories, converters, logic circu
- 8542 32 Memories
- 8542 33 Amplifiers
- 8542 39 Other
- 8543 20 Signal generators
- 8548 00 Electrical parts of machinery or apparatus, not specified or included elsewhere in this ch
- 8807 30 Other parts of aeroplanes, helicopters or unmanned aircraft
- 9013 10 Telescopic sights for fitting to arms; periscopes; telescopes designed to form parts of ma
- 9013 80 Other devices, appliances and instruments
- 9014 20 Instruments and appliances for aeronautical or space navigation (other than compasses)
- 9014 80 Other instruments and appliances
- 9027 50 Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared)
- 9030 20 Oscilloscopes and oscillographs
- 9030 32 Multimeters, with a recording device
- 9030 39 Other, with a recording device
- 9030 82 Other instruments and apparatus: For measuring or checking semiconductor wafers or devices
Annex XLVIII
Additional entries covered by the same due diligence obligation.
- 8502 20 Generating sets with spark-ignition internal combustion piston engines
- 8536 50 Other switches
Frequently asked questions
What are common high priority items (CHP)?
It is a list of CN codes in Annex XL to Regulation 833/2014, considered particularly sensitive to sanctions circumvention: electronics, components, machine tools and parts found in Russian military equipment. Being on the list is not a separate ban, but it triggers due diligence obligations.
What does Article 12gb require?
Anyone who sells, supplies, transfers or exports goods from Annex XL or XLVIII must identify and assess the risk of export to Russia or use in Russia, ensure the assessment is documented and kept up to date, and extend those requirements to non-EU subsidiaries. It is an obligation of process, not a one-off list check.
May goods on the CHP list be exported?
To Russia no, if it is covered by a ban under another article. To third countries yes, but with due diligence and the No Russia clause in the contract. The CHP list says "these goods get diverted to Russia, look closer", not "forbidden".
How many CN codes are in Annex XL?
In our database, against the consolidated text of 24 July 2026, Annex XL has 50 entries and Annex XLVIII 2. The full list with descriptions is below.