Canadian sanctions - Export and import restrictions

Export and import restrictions made under Canadian sanctions legislation prohibit exporting, importing, buying, selling, or shipping identified goods, commodities or technologies to or from a targeted country, as well as providing any financial, technical or other services related to such goods.

The United Nations Act (UNA) and the Special Economic Measures Act (SEMA) have specific restrictions to control the export or transfer of military, dual-use and other strategic goods and technologies, as well as certain other goods controlled for economic reasons, to targeted countries.

There are various lists of goods that may be consulted in the process of verifying if an export or import activity is prohibited under Canadian sanctions.

On this page

• Sanctions - export and import restrictions
• Arms embargoes
• Export Control List

Sanctions - export and import restrictions

Regulations under the Special Economic Measures Act and the United Nations Act may include various prohibitions on exports and imports of certain goods. It is important to review the regulations under each sanctions regime which can be found on the respective act webpage, as well as on the country-specific sanctions pages.

Luxury Goods list – export and import

The Luxury Goods list found in the SEMA Russia Regulations prohibits the export or import, selling, purchasing or acquiring, as well as the supplying or shipping of any luxury good listed.

Revenue-generating goods – import

The Revenue-generating goods list found in the SEMA Russia Regulations prohibits the import, purchasing or acquiring, of any revenue-generating good listed.

Restricted Goods and Technologies List - export

The Restricted Goods and Technologies List includes a broad range of items in the areas of electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation goods that are prohibited for export to Russia under section 3.06 of the SEMA Russia Regulations, and to Belarus under section 3.6 of the SEMA Belarus Regulations. These goods do not have HS Codes associated with them.

Common High Priority List - export

The Common High Priority List (CHPL) was developed by the United States, the United Kingdom, the European Union and Japan, and endorsed by the Global Export Control Coalition (GECC) and the Export Enforcement Five (E5), both of which Canada is a member. This list ensures goods critical to Russian weapons development do not arrive in Russia. Notably, Canada has prohibited all the goods identified in the CHPL under section 3.09 of the SEMA Russia Regulations. The E5 continue to update the list and Canada is committed to ensuring those goods are prohibited for export to Russia.

The CHPL lists products using Harmonized System (HS) codes. This includes electronic components such as integrated circuits and radio frequency (RF) transceiver modules.

The list of six-digit HS codes (HS6) is divided into four tiers from most to least critical. Tiers one and two contain particularly sensitive items:

• Tier 1: Integrated circuits (also referred to as microelectronics).
• Tier 2: Electronics items related to wireless communication, satellite-based radio navigation, and passive electronic components.
• Tier 3: This tier is divided into electronic and non-electronic items to provide greater clarity to the different industries that may work with these items.
• Tier 4: Manufacturing, production and quality testing equipment of electric components and circuits.

For more information, see Preventing Russian Export Control and Sanctions Evasion: Updated Guidance for Industry.

HS code-based vs description-based approaches

Schedules of prohibited goods use a description-based approach “Column 1” to cover items that may cut across multiple HS codes, allowing goods to be identified by their detailed capabilities and technical characteristics. Conversely, the HS codes set out in “Column 2” are provided for reference purposes only. For screening purposes, HS codes may be useful, however, the description in “Column 1” prevails over the HS codes listed in “Column 2”.

Sanctions circumvention risks for listed Harmonized System (HS) codes

Exporters are strongly encouraged to conduct additional due diligence when encountering one of the listed HS codes to ensure end-user legitimacy and mitigate attempts to evade Canada and its allies’ export controls and/or sanctions. HS codes can be found on trade documents including commercial invoices, packing slips, airway bills, sea or house bills, or other supporting trade documentation.

CHPL tier one and tier two HS codes

In reference to the CHPL’s tier one and tier two HS codes, 3 patterns associated with importers in non-GECC countries raise diversion concerns:

1. the company never received exports prior to February 24, 2022;
2. the company received exports that did not include any of the tier one and tier two HS codes prior to February 24, 2022; or
3. the company received exports involving the tier one and tier two HS codes prior to February 24, 2022, but also saw a significant spike in exports thereafter.

Accordingly, exporters and trade facilitators should conduct customer and transactional due diligence prior to export. Specifically, when opening accounts for new customers engaged in trade and located in non-GECC countries, exporters are urged to:

• Evaluate the customer’s date of incorporation (e.g., incorporation after February 24, 2022),
• Evaluate the end-user and end use of the item (e.g., whether the customer’s line of business is consistent with the ordered items), and
• Evaluate whether the customer’s physical location and public-facing website raise any red flags (e.g., business address is a residence, no website is available).

For existing customers, exporters should pay particular attention to anomalous increases in the volume or value of orders. Exporters should also request and review additional information about the end use and end-user, as well as inconsistencies between the items ordered and the customer’s line of business.

The Canadian Sanctions – Red flags page may be helpful to detect suspicious activities.

Dual-use goods

Dual-use goods encompass a wide range of products and technologies that can be employed for both civilian and military purposes. Certain dual-use goods and technologies may be prohibited under specific sanctions regulations. For reference purposes, to help identify and understand what is considered “dual‑use”, a detailed list of goods and technologies defined as dual-use is available in the Export Control List and A Guide to Canada’s Export Control List, published by Global Affairs Canada, as amended from time to time.

Arms embargoes

Canada’s sanctions apply an arms and related materials embargo on a number of countries and entities.

An arms embargo aims to prevent weapons and military equipment from leaving or reaching a targeted country. It prohibits exporting and importing arms and related materials to and from the targeted country and may also prohibit communicating technical data or financial transactions related to military activities.

See Guidance for the Aerospace and Defence Sector for more information on arms and related materials.

Export Control List

While the Export Control List (ECL) does not pertain to obligations under Canada’s sanctions legislation, you may want to consult this list in conjunction with screening for sanctions prohibitions. ECL refers to the obligations under the Export and Import Permit Act (EIPA), which are complementary to Canada’s sanctions export prohibitions.

In some cases, permits may be required under the EIPA, as well as under the SEMA and/or the UNA. While the EIPA is a separate legislation, the covered items may significantly overlap with those covered by sanctions legislation.