Export control glossary for component brokers

The acronyms of sanctions and export controls, defined in plain words. Each entry ends with what it means in practice for a distributor or broker of electronic components, obsolete and end-of-life parts included.

BIS Bureau of Industry and Security

The agency of the US Department of Commerce that writes and enforces the Export Administration Regulations (EAR). It maintains the Entity List, the Unverified List and the Military End-User List, and publishes the Common High Priority List. VetLane screens the BIS publication of that list.

For brokers: BIS rules follow US-origin parts after they leave the US. A broker in Europe or Asia reselling US-made chips is within its reach.

The CHPL guide

EAR Export Administration Regulations

The US regulations (15 CFR Parts 730 to 774) that control exports, re-exports and transfers of items "subject to the EAR": US-origin items wherever they are, foreign-made items with more than a minimal share of US content, and some foreign items made with US technology.

For brokers: An end-of-life US-brand IC bought from stock in Hong Kong is still US-origin. Shipping it on to a third country is a re-export under the EAR.

CCL Commerce Control List

The list of items controlled under the EAR (Supplement No. 1 to Part 774), organised by category, each item with an Export Control Classification Number.

For brokers: Most passive components are not on the CCL. Some ICs, FPGAs, high-speed converters and encryption parts are.

ECCN Export Control Classification Number

The five character code (for example 3A001 or 5A992) that places an item on the Commerce Control List and tells which reasons for control and licence requirements apply.

For brokers: Manufacturers usually publish the ECCN of their parts, and the page often stays online after a part is discontinued. Keep a copy with your records.

EAR99 Items subject to the EAR but not on the CCL

The default classification for items subject to the EAR that are not listed on the Commerce Control List. EAR99 is not a free pass: a licence can still be needed for an embargoed destination, a listed party or a prohibited end use.

For brokers: For Russia and Belarus, Supplement No. 4 to Part 746 adds licence requirements for many EAR99 items, listed by HS code. Common parts are among them.

Entity List BIS Entity List (Supplement No. 4 to Part 744)

Companies, individuals and addresses for which BIS requires a licence, usually reviewed with a presumption of denial, when they are a party to a transaction involving items subject to the EAR. Each entry says which items it covers, often all of them, EAR99 included.

For brokers: Listed parties are often intermediaries: trading companies and forwarders in transit hubs. Some entries are addresses only, shared by several shell companies.

Freight forwarder on the Entity List

Affiliates Rule BIS 50% rule

A BIS rule of September 2025 extending Entity List and Military End-User restrictions to companies owned 50% or more by listed parties. It was suspended for one year from 10 November 2025.

For brokers: Ownership checks, already routine for OFAC sanctions, become part of export screening when the rule applies.

The BIS 50% rule

MEU List Military End-User List (Supplement No. 7 to Part 744)

Foreign parties BIS considers military end users. Exports of certain items to them require a licence.

For brokers: Entries are mostly in China and a few other countries. Screen them like Entity List parties.

UVL Unverified List (Supplement No. 6 to Part 744)

Parties whose legitimacy BIS could not verify during an end-use check. Licence exceptions cannot be used for them and a statement from the party is required before shipping.

For brokers: A UVL match is a red flag even for parts that need no licence: ask why the buyer could not be verified.

ITAR International Traffic in Arms Regulations

The US State Department regulations (22 CFR Parts 120 to 130) controlling defense articles and services on the US Munitions List, administered by the Directorate of Defense Trade Controls (DDTC).

For brokers: Some obsolete parts were designed for military programs. A "military grade" label alone decides nothing: the classification by the manufacturer or the USML category does.

USML United States Munitions List

The list of defense articles under ITAR (22 CFR Part 121), in 21 categories. Electronics designed for military use can fall under Category XI or XV.

For brokers: Parts specially designed for a USML item stay ITAR-controlled when resold as surplus.

OFAC Office of Foreign Assets Control

The office of the US Treasury that administers US economic sanctions, publishes the SDN List and enforces the blocking of assets of listed persons.

For brokers: OFAC reaches you through US persons and US dollar payments: a wire through a US bank to a sanctioned buyer can be blocked.

SDN List Specially Designated Nationals and Blocked Persons List

The main OFAC list: persons and companies whose property is blocked and with whom US persons may not deal.

For brokers: Many Russian procurement networks are on it, along with front companies in third countries.

OFAC 50 percent rule Ownership rule for blocked persons

Under OFAC guidance, a company owned 50% or more, directly or indirectly, individually or in aggregate, by one or more blocked persons is itself blocked, even if it is not named on a list.

For brokers: A clean name check is not enough for a buyer with opaque ownership: look at who owns it.

CSL Consolidated Screening List

A single file published by the US government (trade.gov) gathering the export and sanctions lists of Commerce, State and Treasury, including the Entity List and the SDN List.

For brokers: The quickest way to screen US lists in one pass. VetLane loads it every day.

The lists VetLane screens

CHPL Common High Priority List

Fifty HS codes, in six tiers, of the items at highest risk of diversion to Russia's military industry. VetLane screens the BIS publication of 23 February 2024, and the same codes as Annex XL of Regulation (EU) 833/2014.

For brokers: Most of the list is electronic components: ICs, capacitors, connectors, diodes, transistors. It is the core of a distributor's catalogue.

Quick CHPL Check

HS code Harmonized System code

The international customs classification of goods maintained by the World Customs Organization: the first 6 digits are the same in every country.

For brokers: The CHPL is written in 6 digit HS codes, so a 6 digit match is what counts.

How to map HS codes to the CHPL

CN code EU Combined Nomenclature code

The EU 8 digit code: the 6 digit HS code plus 2 EU digits. EU sanctions annexes often list CN codes.

For brokers: Your EU customs declarations already carry it: use it as the source of truth for your catalogue.

HTS / Schedule B US Harmonized Tariff Schedule and Schedule B

The US 10 digit codes: HTS for imports, Schedule B for exports. Both start with the 6 digit HS code.

For brokers: Supplement No. 4 to Part 746 lists items by HTS-6 code.

Regulation 833/2014 EU Russia sanctions regulation

The EU regulation of restrictive measures concerning Russia, amended by each sanctions package. Its annexes list banned goods by CN code and, in Annex IV, military end users.

For brokers: It applies to EU companies and to any business done in the EU, including sales by an EU broker to a buyer in a third country.

Annex XL Common high priority items (Regulation 833/2014)

The annex of the EU Russia regulation that lists the common high priority items: the same 50 codes as the CHPL.

For brokers: Goods in Annex XL trigger the Article 12g clause when sold to a buyer outside the partner countries.

Article 12g EU "No re-export to Russia" clause

Since 20 March 2024, EU exporters selling goods of Annexes XI, XX, XXXV or XL to a buyer outside the partner countries of Annex VIII must contractually prohibit re-export to Russia and for use in Russia, with adequate remedies.

For brokers: For an EU distributor, most CHPL sales outside the partner countries need this clause in the contract or terms of sale.

End-use statements and clauses

Dual-use items Regulation (EU) 2021/821

Goods, software and technology with civil and military uses, listed in Annex I of the EU Dual-Use Regulation. Exporting them out of the EU requires an authorisation.

For brokers: Some high-end ICs, FPGAs and converters are dual-use; most commodity parts are not. The manufacturer's classification tells you.

OFSI Office of Financial Sanctions Implementation

Part of HM Treasury: enforces UK financial sanctions, including asset freezes on designated persons.

For brokers: Payments to or from a designated person breach UK financial sanctions, whatever the goods.

OTSI Office of Trade Sanctions Implementation

Part of the UK Department for Business and Trade: enforces UK trade sanctions, such as bans on supplying goods to Russia, and publishes guidance on circumvention and high-risk countries.

For brokers: OTSI guidance is the UK reference for red flags and third countries to watch.

UK distributor checklist

ECJU Export Control Joint Unit

The UK unit that issues export licences for controlled goods, hosted by the Department for Business and Trade.

For brokers: A standard individual licence application comes with an end-user and stockist undertaking (EUSU) signed by the buyer.

UK Sanctions List Published by the Foreign, Commonwealth & Development Office

The list of persons and entities designated under UK sanctions regimes, with the measures that apply to each.

For brokers: A UK business screens its customers against it, and it is one of the lists VetLane loads every day.

The lists VetLane screens

End-use statement Also end-user statement or certificate

A signed declaration from the buyer naming the end user, the end use and the final destination of the goods, and committing not to re-export them to prohibited places or parties.

For brokers: For brokers, it is often the only document linking a sale to its real destination.

End-use statements with VetLane

Denied-party screening Also restricted-party screening

Comparing customers, consignees, forwarders and end users with sanctions and export control lists before a sale and when the lists change.

For brokers: Screen every party named on the order, not only the buyer: the forwarder and the consignee count.

Customer and destination screening

Diversion Also transshipment or circumvention

Goods sold to a buyer in a third country and moved on to a prohibited destination, often through trading companies and forwarders in transit hubs.

For brokers: Diversion is why a lawful-looking sale to a new customer in a transit country deserves a second look.

What we flag

Red flags Warning signs

Signs, listed in government guidance, that a transaction may be diverted: a new company buying sensitive parts, a forwarder as consignee, a delivery address different from the billing one, reluctance to give end-use information.

For brokers: One flag proves nothing. A pattern of them calls for questions, documents or a refusal, and a record of what you decided.

The CHPL guide