Common High Priority List
A list, drawn up by the United States with the EU, the UK and Japan, of fifty Harmonized System codes found in Russian weapons, which marks where exporters, banks and cargo insurers must push their due diligence.
The Common High Priority List gathers fifty Harmonized System codes found in Russian weapons and marks where exporters, banks and cargo insurers must push their due diligence. The US Bureau of Industry and Security built the list with the EU, the UK and Japan, from components recovered from Russian missiles and drones in Ukraine. The September 2023 version had forty-five codes, sorted into four tiers; the February 2024 version has fifty. Tier 1 groups four integrated circuit codes, 8542.31, 8542.32, 8542.33 and 8542.39. Tier 2 adds five more, including 8517.62 for data transmission equipment; these nine codes are the most closely watched. Tiers 3 and 4 cover electrical and mechanical components, then manufacturing equipment and CNC (computer numerical control) machine tools. The list's strength lies in the code: a customs officer, a banker or an underwriter can read it off an invoice without knowing the technology. In the EU these items sit in Annex XL to Regulation 833/2014. Article 12g requires the "no Russia" clause in export contracts with third countries. Article 12gb, from the 14th package, requires those selling these goods outside the Union to identify and reduce the risk of diversion to Russia, non-EU subsidiaries included, except toward the partner countries in Annex VIII. Regulation 2025/395 of February 24, 2025 extended that due diligence to the goods in Annex XLVIII. For a cargo insurer the list changes underwriting: a policy on 8542 components shipped to Central Asia, the Caucasus or Turkey raises the question of the end buyer and of the clause in the sales contract. Diversion shows up first in trade flows: a country with no electronics industry whose chip imports suddenly soar.
Textbook case: a cargo insurer receives a declaration under an open cover for 2,000 processors classified 8542.31, at 450 dollars each, sold by a German distributor to a buyer in Yerevan. Insured value: 2,000 × 450 = 900,000 dollars, increased by 10% under the policy, so 990,000 dollars. The code is in Tier 1. The underwriter asks for the sales contract, finds the "no Russia" clause but no end-user certificate, and the buyer, set up six months earlier, has no website and no known industrial activity. He declines the declaration and records the reason in the file.
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