Basis of Regulations No. 833/2014, No. 267/2012, and No. 2021/821

Within the framework of these regulations and their implementation in German foreign trade law, it concerns the obligations of economic operators, the reporting, approval, and documentation of these business transactions through End-Use Certificates (EVE).

Regulation (EU) No. 833/2014 (Russia Sanctions)

Content: This is the central regulation on restrictive measures in view of Russia's actions. It has been massively expanded since 2022 through numerous packages (most recently the 20th package in February 2026).

Article 12g: It obliges exporters to use the so-called "No-Russia Clause".

Annex XL: Here, the "Common High Priority Items" are listed (including your bearings KN 8482), for which a particularly strict review of the end-use in third countries is prescribed to prevent circumvention transactions.

Measures: 

1. Mandatory End-Use Certificates (EVE)  - see forms at the end of the page

2. Download Sanction-declaration

Regulation (EU) No. 267/2012 (IRAN Sanctions)

Content: This is the legal basis for requiring an End-Use Certificate EVB Template C4 for deliveries to Iran.

Measures: Rejection of business transactions related to the destination country Iran, even for approved transactions.

Regulation (EU) No. 2021/821 (Dual-Use)

Content: This regulation governs the export, brokerage, technical assistance, and transit of dual-use goods (civil and military).

Assessment:

1. Are bearings subject to the Dual-Use Regulation (2021/821)?

Generally: No. Most standard industrial bearings do not meet the extremely high technical requirements of Annex I of the Dual-Use Regulation. Bearings are only controlled under numbers 2A001 (high-precision bearings) or 2B001.

→ The thresholds: Bearings are only considered "true" dual-use goods if they have, for example, tolerances according to ABEC 7 or ABEC 9 (or better).

2. Can we issue a "Non-Dual-Use" declaration?

Yes, but with a crucial addition. We can confirm that the bearings are not listed in Annex I of Regulation 2021/821. However, this exemption is broken by the supplementary Regulation No. 833/2014 (Russia Sanctions) and counteracted by the "Catch-all" clause.

Download Dual-Use

Relevance for the EVE: In the annexes of this regulation (Annex I), the goods are listed for which BAFA mandatorily requires an EVE (usually Template C1 or C2). It also defines the "Catch-all Clauses", according to which an EVE may be necessary even for non-listed goods if a critical end-use is suspected.

"Export and transfer of dual-use goods of Annex I, Annex IV of the EU Dual-Use Regulation or Part I Section B of the Export List
For the direct and indirect export of goods listed in Annex I of the EU-Dual-Use Regulation or in Part I Section B of the Export List to Russia or for use in Russia, please use the new Annex C 7 instead of Annex C 1.
If you are applying for a general license for export to dealers or distribution companies for resale, please use Annex C 2. For submitting End-Use Certificates when applying for general licenses for other business models, please contact the responsible department 223 of the BAFA."
 See Link

Which products are affected 

Roller bearings are listed in Annex Part B