8 Oct 2026
Selling Electronics, Drones or Optics Internationally? Export Controls and Sanctions for Shopify Merchants
How export controls differ from sanctions, what EAR99 and ECCNs mean, the Common High Priority List, the August 2026 US drone rule, EU dual-use and Russia rules, and a workflow for technical products.
Last reviewed: 8 October 2026. Export classification depends on exact technical specifications. Use this guide to recognize when you need to classify or seek a licence, not as a classification. It is not legal advice.
Quick answer
Sanctions screening asks who you're selling to. Export controls ask what you're sending and where it ends up. If you sell electronics, drones and drone parts, cameras, thermal imagers, night-vision or rifle optics, radios, GNSS receivers, encryption hardware or similar technical goods, both apply.
Most consumer goods need no licence to most destinations. But "most" is doing a lot of work: the same item can be freely exportable to France and need a licence to Russia, Belarus, Iran or China, or to a particular end user. Shipping to a restricted destination via an intermediary doesn't change the rules.
Sanctions vs export controls
| Sanctions | Export controls | |
|---|---|---|
| Main question | Is this party or country one I can deal with? | Does this item need a licence for this destination, end use or end user? |
| US authority | OFAC (Treasury) | BIS (Commerce), under the Export Administration Regulations (EAR) |
| EU basis | Council regulations such as 269/2014 and 833/2014 | Dual-Use Regulation (EU) 2021/821, plus country-specific goods bans such as Regulation 833/2014 for Russia |
| UK basis | Sanctions regulations under the Sanctions and Anti-Money Laundering Act 2018 | Export Control Order 2008, plus trade sanctions in the country regulations |
| What a merchant checks | Names on the order and the destination | Product classification, destination and end use |
In practice the two overlap. Russia restrictions in the EU, UK and US are partly sanctions and partly export controls, and both regimes prohibit indirect supply through third countries.
US: ECCNs, EAR99 and licence requirements
Under the EAR, an item is either listed on the Commerce Control List (CCL) with an Export Control Classification Number (ECCN), or it falls into the catch-all EAR99.
- EAR99 covers most low-technology consumer goods. They can generally be shipped to most destinations without a licence. Even EAR99 items need a licence when they go to an embargoed or sanctioned destination, to a restricted party, or towards a prohibited end use.
- ECCN-listed items need a licence only for the destinations and reasons for control that the ECCN specifies, unless a licence exception applies.
For Russia and Belarus, BIS requires a licence for every item on the CCL, for luxury goods listed in Supplement No. 5 to Part 746, and for wide categories of other items identified by tariff code in Supplements No. 2, 4 and 6 to Part 746. Licence exceptions are limited. In practice many EAR99 consumer goods sold online are caught.
Drones, August 2026. On 13 August 2026, BIS issued a final rule easing controls on many commercial UAVs. It removed National Security Column 2 controls from ECCN 9A012.a, dropped wind-gust tolerance as a control parameter, and raised the endurance threshold for national security controls from 30 minutes to three hours. Drones below that threshold remain controlled for anti-terrorism reasons. Heightened controls remain for UAVs with specified lasers, thermal imaging or navigation systems. Military end-use and end-user restrictions are preserved. The rule makes classification more favorable for many hobby drones. It doesn't lift the Russia, Belarus or Iran restrictions or the end-user rules.
EU: dual-use and the Russia annexes
- Regulation (EU) 2021/821, the Dual-Use Regulation, requires an authorization to export items listed in its Annex I outside the EU. Most consumer electronics are not listed, but some items with encryption, thermal imaging, high-performance cameras or navigation functions can be.
- Regulation (EU) No 833/2014 separately bans many goods to Russia. Annex VII covers advanced technology, including many electronic components, and Annex XXIII covers goods that could enhance Russian industrial capabilities. The Russia ban applies even to goods that are not dual-use under Regulation 2021/821.
- UAV parts to Iran. EU rules also restrict the export of components used in the production of unmanned aerial vehicles to Iran.
The Common High Priority List
The Common High Priority Items List (CHPL) is a list of goods, identified by Harmonized System (HS) code, that the US, EU, UK and Japan identified in Russian weapons systems recovered on the battlefield. The February 2024 version has 50 HS codes across tiers:
| Tier | What it covers |
|---|---|
| 1 | Integrated circuits (4 HS codes) |
| 2 | Wireless communication, satellite navigation and passive electronic components (5) |
| 3.A | Discrete components, plugs and connectors, navigation equipment and digital cameras (16) |
| 3.B | Mechanical and non-electronic components (9) |
| 4.A | Manufacturing and test equipment for electronics (11) |
| 4.B | CNC machine tools and components (5) |
Why it matters to online stores:
- In the EU, CHPL goods are listed in Annex XL of Regulation 833/2014. Sales of them to buyers outside the EU and the partner countries need the "no re-export to Russia" clause under Article 12g.
- Authorities expect enhanced due diligence on buyers of CHPL items, particularly in countries named as transshipment points. See freight forwarder red flags.
- The BIS CHPL page publishes the current list for US exporters.
A practical workflow for technical products
- Classify your catalog once. For each product, record its HS code and, for US-origin goods or US exports, its ECCN or EAR99 status. For EU exports, check Annex I of Regulation 2021/821 and the Russia annexes. Manufacturers often publish ECCNs; ask them if they don't.
- Map products to restricted destinations. Decide which products you won't ship to which countries, and configure Shopify Markets and shipping zones to match.
- Add the no-Russia clause to your terms if you are an EU seller of Annex XL, XXXV, XI or XX goods to non-partner countries.
- Screen every order's parties against sanctions and denied-party lists. For US exporters, the Consolidated Screening List brings together the Entity List, the Denied Persons List and other export-control lists alongside OFAC lists.
- Look at quantity and fit. Ten thermal cores to a consumer address is a different risk from one.
- Hold, ask and record when something doesn't fit.
Where MatchAudit helps, and where it doesn't
To be clear about scope: MatchAudit does not classify products or determine whether an item needs an export licence. That remains your classification work, or your customs broker's.
What the MatchAudit Shopify app does cover is the party and destination side of export compliance:
- US Consolidated Screening List as a source, which includes BIS's Entity List and Denied Persons List alongside other export-control and sanctions lists, plus OFAC, EU, UN, UK, Swiss and other lists you select.
- Billing and shipping country checks with your own stricter rules. If your policy is "no drone parts to country X," you can mark country X restricted so every order there is held for a person to check the products.
- A trigger for your own product logic. The Shopify Flow action Screen order for sanctions lets you screen orders on events MatchAudit doesn't watch by default. For example, run it when an order is tagged
exportor contains a product from a controlled collection. - Evidence: each decision stores the parties screened, the list versions, the country assessment and the reviewer's rationale. You can record your classification reasoning in that rationale.
Selling technical products abroad? Install MatchAudit from the Shopify App Store to make sure denied and sanctioned parties never reach fulfillment, while you handle product classification.
Frequently asked questions
Do I need an export license to sell drone parts online? It depends on the part's classification, the destination and the end user. Many commercial drone items are EAR99 or controlled only for anti-terrorism reasons, especially after BIS's 13 August 2026 rule. Exports to Russia, Belarus or Iran, to listed parties, or for military end uses can still require a licence or be prohibited.
Which products are restricted from export to Russia? In the EU: luxury goods above €300 per item (Annex XVIII), dual-use and advanced technology items (Annexes I and VII), industrial goods (Annex XXIII), Common High Priority Items (Annex XL) and more. In the US: all CCL items, Supplement No. 5 luxury goods, and broad categories of other items by tariff code. The UK has its own lists.
What does EAR99 mean? An item subject to the EAR that isn't listed on the Commerce Control List. It can generally be shipped to most destinations without a licence, but not to embargoed destinations, prohibited end users or prohibited end uses.
Does a sanctions screening app check whether my product needs a licence? MatchAudit doesn't. It screens the parties and destinations on an order. Product classification is a separate step.
Related reading
- Freight forwarders and reshipping: red flags
- EU and UK sanctions rules for online shops
- Can I ship to Russia from Shopify?
Official sources
- BIS, Common High Priority Items List (CHPL): bis.gov
- European Commission, List of Common High Priority Items (February 2024): finance.ec.europa.eu
- Export Administration Regulations, Part 746 (Embargoes and other special controls): ecfr.gov
- International Trade Administration, Consolidated Screening List: trade.gov
- Regulation (EU) 2021/821 (Dual-Use Regulation): eur-lex.europa.eu
- Council Regulation (EU) No 833/2014 (consolidated): eur-lex.europa.eu
- Arnold & Porter, BIS final rule easing drone export controls (August 2026): arnoldporter.com
Related reading
Best Sanctions Screening Apps for Shopify (2026): Compared
A dated comparison of the sanctions screening apps on the Shopify App Store, covering lists, fulfillment holds, review workflow, evidence and pricing, sourced from each app's public listing.
How to Screen Shopify Orders Against OFAC, EU, UK and UN Sanctions Lists (and Keep Proof)
A step-by-step sanctions screening process for Shopify: which lists to use, which names to screen, how to handle false positives, how to decide a possible match, and what records prove you screened.
