Russia Tightens Export Controls... Military-Use Possible Items Must Obtain Permission

Expansion of Items Requiring Permission for Russia and Belarus to 1,402 Products

The government is strengthening export controls on Russia and Belarus. Items with a high likelihood of being used for military purposes, such as metal cutting machines, optical device components, and sensors, will in principle be prohibited from export, and only items with approved permits will be allowed for export.

The Ministry of Trade, Industry and Energy announced on the 5th that it will implement the revised "35th Strategic Items Export and Import Notice," which expands the list of items requiring permits for the Russia-Belarus situation, starting from the 9th. The situation permit system requires government approval for exports of items that are not strategic goods but have a high possibility of being diverted for military use.

With this revision, 243 items have been added, expanding the total number of items requiring situation permits for Russia and Belarus to 1,402. The newly added items include metal cutting machines, machine tool components, optical device components, sensors, and other items with a high potential for military diversion.

Items newly added to the situation permit list will, in principle, be prohibited from export once the revised notice is enforced. However, exports under existing contracts signed by September 8 and exports to local subsidiaries of domestic companies may apply for situation permits if they meet case-by-case review criteria. Only exports with issued permits will be allowed.

In addition, considering the recent increase in cases of circumvention of export controls through indirect exports, the Ministry of Trade, Industry and Energy will also revise and implement (on September 9) the "Administrative Sanctions Guidelines for Violators of Strategic Item Exports," which strengthens administrative penalties for intentional violations. The revised guidelines will increase the severity of administrative sanctions for repeat and intentional violators, while allowing minor cases (first-time violations with export amounts under $1,000) to be closed internally. It also establishes grounds for administrative sanctions against those who fail to comply with conditional permits.

The Ministry plans to strengthen crackdowns on unauthorized exports and indirect exports of strategic items and items requiring situation permits in cooperation with related ministries.