What is the Common High Priority List (CHPL) and how to screen it
The Common High Priority List (CHPL) is a list of 50 goods, identified by their 6 digit HS code, that Russia seeks for its military industry and that are most at risk of reaching it through third countries. For an electronic component distributor, it is the list that matters most: most of its codes are the parts on your shelves.
Who publishes the CHPL
VetLane screens the Common High Priority Items List published by the US Bureau of Industry and Security (BIS), version of 23 February 2024, transcribed from that publication. The same 50 codes are also screened as Annex XL of Regulation (EU) 833/2014. The United Kingdom and Japan publish their own pages of this list; those files are not loaded.
The 50 codes in six tiers
The codes are grouped in tiers by priority. Tiers 1 and 2, nine codes in all, are the ones BIS prioritises most.
| Tier | Codes | What it covers |
|---|---|---|
| Tier 1 | 4 | Tier 1 holds the integrated circuits Russia needs most and has the least capacity to replace. It is the first place enforcement looks. |
| Tier 2 | 5 | Tier 2 covers electronics for which Russia may have some domestic production but prefers sources in the US and partner countries. |
| Tier 3A | 16 | Tier 3A covers further electronic components such as transistors, diodes and connectors, with a broader base of suppliers. |
| Tier 3B | 9 | Tier 3B covers mechanical and other components such as bearings, aircraft parts, optical devices and navigation instruments. |
| Tier 4A | 11 | Tier 4A covers equipment used to manufacture and test electronic components, circuit boards and modules. |
| Tier 4B | 5 | Tier 4B covers computer numerically controlled (CNC) machine tools and their components. |
Examples you will recognise: 8542.31 processors and controllers (Tier 1), 8532.24 multilayer ceramic capacitors (Tier 2), 8536.69 plugs and sockets (Tier 3A) and 8482.10 ball bearings (Tier 3B). The full list of CHPL codes by tier links to a page for each.
Why it matters for distributors and brokers
Russia rarely buys these parts directly. It buys through intermediaries: trading companies and freight forwarders in third countries, often recently created, that resell to the real end user. BIS warns exporters, re-exporters and their service providers that this is how listed parties and true end users are hidden. A distributor selling a CHPL part to a new customer in a transit hub is exactly where that chain starts.
- In the EU, Article 12g of Regulation 833/2014 requires, since 20 March 2024, a contractual "no re-export to Russia" clause for Annex XL goods, the same 50 codes, sold to a buyer outside the partner countries of Annex VIII.
- In the UK, government guidance on countering Russian sanctions evasion builds on the CHPL and recommends a "No Russia" clause and enhanced due diligence for these items.
- In the US, items in Tiers 1 and 2 are subject to the most comprehensive controls of the Export Administration Regulations; some are EAR99, others are on the Commerce Control List.
Red flags to look for
Government guidance lists warning signs of diversion. None proves anything on its own; together they tell you where to look harder.
- A buyer in a transit country named in UK or US guidance, such as Türkiye, the UAE, Kazakhstan, Armenia or Hong Kong.
- A company created after 24 February 2022, buying high-priority items with little trading history.
- A freight forwarder as consignee, or a delivery country different from the billing country.
- Several trading companies at one address, or a company registered at a home.
- No website, no domain email, or reluctance to say who will use the parts.
- A name close to a listed party, including transliteration variants.
How to screen your sales against the CHPL
- Give every catalogue line an HS code. At least 6 digits; your customs CN or HTS code is fine. See how to map HS codes to the CHPL.
- Compare the first 6 digits with the 50 codes. Check a code with the Quick CHPL Check, and look again at parts classified under a heading that holds listed codes.
- Screen every party to a CHPL sale: buyer, consignee, forwarder and end user, against the US, UK, EU and UN lists. A free account checks one company at a time.
- Check the destination and the route, not only the name: transit countries, mismatched addresses, forwarders.
- Get the paperwork: the Article 12g clause in the EU, a "No Russia" clause and an end-use statement where guidance recommends it. See end-use statements.
- Keep a dated record of what you checked, against which list version, and what you decided. See the audit trail.
- Screen again when the lists change. A customer clean last month can be listed this week.
Official sources
- BIS: Common High Priority Items List
- GOV.UK: Russia sanctions, Common High Priority Items List
- EUR-Lex: Council Regulation (EU) No 833/2014
- European Commission: guidance on the "no re-export to Russia" clause
This guide explains public rules and guidance as of its review date. It is not legal advice; for a specific transaction, speak to an export control lawyer.
Put it into practice
Check an HS code with the Quick CHPL Check and screen a buyer with a free account. When you want it done for every sale, with a sealed record, VetLane runs the routine for you.
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