Export control in Russia: what your buyer needs from you to clear high-tech goods

31 October 2025Trade Pulse

Key point. Part of the high-tech range — electronic components, instruments, communications hardware, specialised machinery, software and technology — falls under Russian export control as military or dual-use products. For those items customs clearance in Russia is impossible without an export control conclusion, known in the trade as Ekskont, and that conclusion is issued only after an identification examination of the goods. The examination runs on technical data that nobody but the manufacturer or the supplier holds, which is why your Russian buyer will come back to you with questions about specifications, composition and intended use. Below is what this means for your shipment and what to prepare before the goods leave your warehouse.

Why a high-tech shipment can stop before it is even declared
Law 183-FZ: what the Russian side is screening for
The identification examination and the Ekskont conclusion
What this means for your shipment
Steps for the shipper before loading
Frequently asked questions

Why a high-tech shipment can stop before it is even declared

Every supplier of technically complex goods sooner or later runs into the same question from the Russian side: is this product classified as a military or dual-use item? If the answer is yes, the goods are subject to state control under Russian law, and moving them across the border legally requires more than an accurate declaration — it requires a package of permits, the export control conclusion among them.

For you as the shipper the practical consequence is simple: the buyer cannot solve this on the commercial documents alone. The question is answered from the technical characteristics of the item, and those come from your datasheets, not from the invoice. A separate case is hardware with cryptographic functions: encryption devices have their own permit document, a notification, in addition to whatever export control requires.

Law 183-FZ: what the Russian side is screening for

The governing act is Federal Law No. 183-FZ of 18 July 1999 «On Export Control». It regulates foreign trade in goods that could be used to create weapons of mass destruction, their means of delivery, other armaments and military equipment, or in the preparation or commission of terrorist acts.

The law establishes:

lists of controlled goods and technologies;
the mechanism for carrying out the examination;
the requirements for obtaining permit documents;
liability for breaching export control rules.

Note the first point in particular. Control is anchored to lists of goods and technologies, not to the buyer's line of business or to your intentions. A perfectly ordinary catalogue item that you sell worldwide without formalities can be caught by a single technical parameter. That is also why permits and certification and permit documents should be treated as part of the lead time on a Russian order, not as an afterthought once the goods are packed.

Export control in Russia: what your buyer needs from you to clear high-tech goods

Without an export control conclusion, high-tech cargo is not cleared in Russia — and the examination runs on the shipper's technical documents

The identification examination and the Ekskont conclusion

Before the customs clearance procedure can begin, the goods go through an identification examination. Its purpose is to establish whether the item falls within the scope of the export control law.

The examination is carried out by:

the Federal Service for Technical and Export Control of Russia (FSTEC);
licensed specialised organisations.

The outcome is the export control conclusion (Ekskont) — an official permit document, without which no further clearance of the cargo is possible. It is what keeps the transaction inside national security requirements and international agreements, protects the commercial interests of both sides, and, in plain operational terms, keeps the cargo out of fines and delays at the border.

The examination comes before the declaration, not alongside it. If the goods arrive at the border while the conclusion is still being obtained, they simply wait in a temporary storage warehouse — and in your buyer's records that shows up as your delivery being late, not as a regulator being slow.

Everything the examining body works from is technical: designation, parameters, composition and materials, functional description, intended use. In shipments of electronic components and similar high-tech goods, the follow-up questions are usually addressed to an engineer, not to a sales manager — and they come back to the manufacturer.

What this means for your shipment

Situation	What happens on the Russian side	What the shipper provides
Goods clearly outside the control lists	Declared and cleared as ordinary cargo	A technical description precise enough to prove the parameters
Parameters that may fall under the lists	Identification examination first, Ekskont, only then the declaration	Datasheets, specifications, composition and materials, intended use
Goods shipped before the conclusion is issued	Cargo waits in temporary storage; delivery date slips	Fast, technically competent answers to follow-up questions
Documents contradict the technical description	The check drags on; permits may be missing altogether	One consistent set: contract, invoice, packing list, datasheet

The transport mode does not change any of this. Whether the consignment moves by air, sea, rail or road, what matters is that the documents are complete and consistent with the law's requirements — and the same end-to-end handling of the shipment applies in each case. Mistakes at this stage are expensive on both sides: delays at customs, confiscation of the cargo, and in serious cases a halt to the counterparty's foreign trade activity.

Steps for the shipper before loading

Ask your buyer under which code the goods will be declared in Russia and whether that code and the product's parameters bring it into the control lists.
Prepare the full technical package in English or Russian: datasheet, specifications, materials and composition, functional description, intended use, photographs.
State explicitly whether the product has cryptographic functionality — encryption hardware carries its own document requirement on top of export control.
Keep one version of the truth: model designation, parameters and product description must read identically in the datasheet, contract, invoice and packing list.
Fix in the contract who obtains the Ekskont, at whose cost, and at what point — and treat it as a condition of shipment, not as paperwork that follows the goods.
Build the examination into your lead time from the moment the order is confirmed, not from the moment the goods are ready.
Nominate an engineer who can answer the examining body's technical questions quickly; every day of silence is a day the cargo does not move.
For controlled items, do not despatch until the buyer confirms the conclusion has been issued.

Frequently asked questions

The Russian importer files the declaration — why is this my problem?

Because the examination is carried out on documents that only you hold. Formally the permits are obtained on the Russian side, but the technical evidence behind them — specifications, composition, intended use — comes from the manufacturer or the supplier. If it arrives late or contradicts the shipping documents, the cargo waits.

My product is a standard commercial item sold worldwide. Can it still be controlled?

It can. The law works from lists of controlled goods and technologies, and an item is measured against them by its technical parameters, not by how routinely it is traded. A definitive answer comes only from the identification examination.

Who issues the conclusion, and what is it worth without one?

The examination is performed by FSTEC of Russia or by licensed specialised organisations, and the result is the export control conclusion. Without it, further clearance of the cargo is not possible — there is no workaround at the border.

What is the real risk if we ship anyway and sort it out later?

Delays at customs are the mildest outcome. The law also provides for liability for breaching export control rules, and in practice that can extend to confiscation of the cargo and a stop to the counterparty's foreign trade operations. A shipment held at the border is recoverable; a buyer who cannot import is not.

Summary

High-tech goods bound for Russia are screened against the control lists of Law 183-FZ, and where they fall within them the shipment cannot be cleared without an export control conclusion issued after an identification examination. That examination is fed by your technical documents, so the schedule of your delivery depends on how quickly and how precisely you supply them. Agree in the contract who obtains the conclusion, start the process when the order is confirmed, and keep the technical description identical across every document in the set. Request a consultation, and we will review your specific product and shipment.

We will check whether your goods fall under Russian export control, arrange the identification examination and clear the shipment on arrival.

Request a consultation