Goods Risk Layers

1. The Core Idea

A TARIC lookup answers "what duties and measures apply to this code?" — not "should this shipment go ahead?"

A good can be entirely legal to export to a third country and still be critical to the Russian or Belarusian military, restricted for direct shipment to RU/BY, and routinely diverted through a handful of transit countries. TARIC alone does not see any of that.

So a goods compliance check on the platform runs layers on top of the classification. Each layer is a separate, independent source, and each answers a different question:

Any layer firing sets review_required on the result. The platform never returns a silent "green light" on a good that lit up a layer.

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2. The Layers

2.1 RU/BY goods-sanctions overlay — property of the destination

Runs only when the destination is Russia or Belarus. It checks whether the CN code (or its heading) is named in the annexes of Regulation (EU) 833/2014 (Russia) or 765/2006 (Belarus), and returns the specific annex, its description and the restriction type (export / transit / import / re-export control).

This is the only layer that is close to binary: a named code in an export annex is a real prohibition, not a review signal.

2.2 CHPL — Common High Priority Items — property of the good

The EU/G7 list of roughly 50 goods most frequently diverted to Russia's defence industry, matched on the HS-6 prefix and carrying a tier (Tier 1 = highest priority). A CHPL hit is not an export ban by itself — it means the item is on the list that customs authorities across the EU and G7 watch for diversion, so the end-user and end-use need verifying.

Note the overlap: Annex XL of Regulation 833/2014 is the Common High Priority Items list inside the sanctions regulation. When both the CHPL layer and the sanctions overlay fire on a RU shipment, that is two independent sources agreeing on the same good.

2.3 EU Dual-Use — property of the good

Correlation to a control entry in Regulation (EU) 2021/821 Annex I (categories 0–9, where Category 1 covers special materials and "chemistry"). Returned as ECCN-style codes (e.g. 3A502, 4A001, 2B003) with their category. Whether the item is actually controlled depends on technical parameters the CN code cannot carry — so this is a candidate signal for an analyst, never a classification.

2.4 EU Military List — property of the good

There is no CN ↔ Military List correlation table — CN is too coarse, and one CN heading holds both civil and military items. So the military layer is reachable only by product-description keyword match, never by code alone. Supply specification text to make it work.

2.5 EU regime-specific goods controls — property of the good

About twenty further EU regimes where a CN code or product text correlates to a controlled-goods annex — among them CBAM (carbon border adjustment), the Deforestation Regulation, Conflict Minerals (3TG), the Anti-Torture Regulation, F-gas and ozone-depleting substances, drug and explosives precursors, the Kimberley Process, cultural goods, mercury, POPs, waste shipments, civilian firearms and the Battery Regulation. Each returns its regulation, the matched control code and a specific next action. Severity varies from a due-diligence prompt to a licence-review flag; none is an automated determination.

2.6 Corridor escalation — property of the route

If a good has fired any of the goods layers and the destination is one of the RU/BY sanctions-evasion transit countries — TR, KZ, AM, AZ, GE, KG, UZ, TJ, TM, AE (Türkiye, the Caucasus, Central Asia and the UAE) — the result recommends enhanced end-user screening: export to these destinations is legal, but re-export to Russia or Belarus is the primary risk, so the consignee should be screened against OFAC, EU, UN and the regional lists and the end-use confirmed before shipping.

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3. Worked Examples

Six goods, verified against the live engine on 2026-09-02. Reproduce any of them with check_trade_compliance or get_compliance_report using the CN code and country shown, plus a short product description.

3.1 Processing units → Türkiye

CN 8471500000 (processing units) → TR

Result: review_required = true.

Why. Export to Türkiye is legal — TARIC on its own would say "fine". But the good is on the high-priority list and correlates to dual-use entries, and Türkiye is a documented re-export corridor. Three signals TARIC never sees.

3.2 The same units → Russia

CN 8471500000 → RU

Result: review_required = true.

Why. A direct RU shipment triggers the sanctions layer, and the code lands in four annexes at once. Annex VII and Annex XL independently confirm the platform's own dual-use and CHPL layers — three sources converging on one good.

3.3 Machine-tool parts → Kazakhstan

CN 8466936000 (parts and accessories for machine tools of headings 8456–8461) → KZ

Result: review_required = true.

Why. Machine-tool tooling is legal to export to Kazakhstan, but it is a high-priority item and Category 2 dual-use equipment (CNC machinery — classic weapons-production kit), and Kazakhstan is a corridor country. TARIC "green", the goods layers and the end-user recommendation are not.

3.4 Integrated circuits → Armenia

CN 8542310000 (electronic integrated circuits: processors and controllers) → AM

Result: review_required = true.

Why. Microchips are the number-one high-priority item (Tier 1), and Armenia is a corridor country. The dual-use layer honestly stays silent — the official CN ↔ ECCN table does not map this exact code — which shows the layers are independent data sources, not copies of each other: CHPL raised the flag where dual-use has no correlation.

3.5 Ball bearings → Russia

CN 8482101000 (ball bearings) → RU

Result: review_required = true.

Why. Bearings are a textbook "battlefield good" — critical to vehicle and equipment production and heavily re-exported. A direct RU shipment fires the full stack: sanctions annexes + CHPL + dual-use all converge on one code.

3.6 Tungsten powder → UAE

CN 8101100000 (tungsten, powders) → AE

Result: review_required = true.

Why. Tungsten powder is a controlled Category 1 dual-use material but not on the narrow CHPL list. It also lands on the UAE's own control list and inside the EU Conflict Minerals regime, and the UAE is a corridor country. "Dual-use without CHPL", plus two further independent regimes firing on their own.

What the six show

• 3.1, 3.3, 3.4, 3.6 — export is legal, and TARIC alone would say "fine". The platform raises 2–3 additional layers and recommends screening the end-user. That is the value TARIC on its own cannot give.
• 3.2, 3.5 — direct RU shipments: the sanctions overlay adds the specific annexes of Regulation 833/2014, and Annex VII / XL independently confirm the platform's own dual-use and CHPL classification.
• The layers are independent sources: 3.4 and 3.6 show CHPL and dual-use firing separately, filling each other's gaps rather than duplicating.
• Any hit on any layer sets review_required — the result is explicitly flagged for a specialist, never given a default green light.

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4. What The Result Looks Like

A goods compliance result stacks:

• Customs classification — HS / CN / TARIC (see HS / CN / TARIC Classification)
• Duties and measures — TARIC
• RU/BY goods sanctions overlay — the annex-level matches
• Goods risk layers — CHPL, dual-use, military, and the EU regime-specific controls, each with its regulation citation, matched control code and recommended action
• Corridor escalation — the end-user-screening recommendation, when the route calls for it

Every hit carries review_required, the source evidence and the legal reference it came from. In the HTML report these appear under the amber "Risk signals — not restrictions" heading, with the line "These signals trigger enhanced review but do not prohibit the transaction by themselves." — audit-ready as it stands.

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5. What This Is Not

• Not an export-licence decision. Every layer except the sanctions overlay is a candidate signal. Whether a licence is required depends on technical parameters, end-use and end-user that a code cannot carry — that call stays with the customer's export-control analyst.
• Not an export ban — unless the RU/BY sanctions overlay names the code in an export annex. A CHPL or dual-use hit on its own is a diversion-risk flag, not a prohibition.
• Not a substitute for description-based export-control search. The layers here are what fires automatically from a code plus optional product text. The full candidate search across EU, UK, US, Japan and Taiwan control lists is a separate, broader tool — see Export-Control Coverage.

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6. Related Material

• HS / CN / TARIC Classification — the customs-classification layer these sit on top of
• Export-Control Coverage — the description- and chemical-identifier-based candidate search across five jurisdictions, and why a bare CN code finds almost nothing
• Prompt Scenarios: Trade, Customs & Logistics — live-tested prompts for running these checks