# Restrictions on goods in Chinese banks

> HS-code lists of goods restricted by Chinese banks (CZCB, Huaxia, Zhejiang Mintai, Everbright): EU-sanctioned items, semiconductors, bearings. Key for trade routing.

Author: Гордей Болотько — партнёр, Corporate & Commercial (https://wiki.private.law/authors/bolotko)
Last modified: 2026-06-04T06:09:00.000Z
Canonical: https://wiki.private.law/en/china-bank-restrictions
Topics: banking
Jurisdictions: china
Functional tags: chinese-banking
Semantic tags: chinese-banking

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Chinese banks have become one of the tightest chokepoints in Russia's foreign trade. Since the start of 2024, lenders from the largest state institutions down to small regional players have refused or stalled payments tied to entire categories of goods, screening each transaction by the commodity code on the invoice. The tables on this page record which goods specific banks have flagged, and the reason they behave this way sits almost entirely in Washington.

## Why a Chinese bank cares about a Russian invoice

The trigger is U.S. Executive Order 14114, signed on 22 December 2023. It lets [OFAC](https://wiki.private.law/en/ofac) sanction any foreign financial institution that conducts or facilitates a significant transaction, or provides any service, involving Russia's military-industrial base. The bank need not act knowingly, and the transaction itself needs no U.S. nexus. A correspondent relationship in dollars is enough to put the institution's access to the U.S. financial system at stake.

OFAC widened the net on 12 June 2024 by redefining Russia's military-industrial base to cover every person already designated under Executive Order 14024. That swept in thousands of ordinary Russian companies and banks rather than defence firms alone, so a Chinese bank now assumes that almost any sanctioned Russian counterparty can carry secondary-sanctions exposure.

Everything turns on dollar clearing. A mid-sized Chinese bank reaches the dollar through a [correspondent network](https://wiki.private.law/en/correspondent-banking-safeguarding) that runs through New York, and losing it would cut the bank off from most of world trade. Set against that, the revenue from any single Russian client is trivial, which is why the threat bites even when no payment ever touches the United States.

> 💡 In practice the banks over-comply. Rather than weigh each payment on its merits, most screen by Harmonized System (HS) code and decline anything that looks sensitive, even where the underlying trade is lawful. A wrong call can cost dollar access, so caution wins by default.

## How the 2024 freeze unfolded

The first shock came in February 2024, when Zhejiang Chouzhou Commercial Bank, the main settlement channel for Russian importers, halted all transactions with Russia and Belarus across every system: SWIFT, the Russian SPFS and China's own CIPS. Within weeks the three largest state banks, ICBC, China Construction Bank and Bank of China, stopped accepting payments from sanctioned Russian institutions.

Business then migrated to smaller and border-region banks, which tightened their own rules each time U.S. enforcement signalled a new round. The result is the uneven map captured below: a payment that one bank clears without comment, another rejects on sight, and the same bank may change its position from one quarter to the next.

## The list behind the lists: HS codes

The codes the banks watch follow the Common High Priority List, roughly fifty six-digit HS codes that the United States, the EU, Japan and the UK jointly treat as critical to Russian weapons programmes. The list runs across four tiers, with the top tiers covering integrated circuits and radio-frequency modules recovered from missiles and drones in Ukraine. Most entries are dual-use electronics, and many overlap with [goods under EU sanctions](https://wiki.private.law/en/goods-under-eu-sanctions). HS heading 8471, which appears in the tables below, simply means computers and data-processing units.

What follows is what individual banks have actually blocked or restricted, drawn from payment practice rather than published policy. Banks almost never announce these rules, so treat the lists as a working snapshot that each institution keeps adjusting to its own appetite for risk.

# Zhejiang Chouzhou Commercial Bank (CZCB)

| Code | Description |
| 8471.50 | Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units |
| 8471.80 | Units of automatic data processing machines, other than processing units, input or output units, and storage units |
| 8482.10 | Ball bearings |
| 8482.20 | Tapered roller bearings, including cone and tapered roller assemblies |
| 8482.30 | Spherical roller bearings |
| 8482.50 | Other cylindrical roller bearings, including cage and roller assemblies |
| 8504.40 | Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters |
| 8517.62 | Apparatus for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus |
| 8517.69 | Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network |
| 8525.89 | Television cameras, digital cameras and video camera recorders |
| 8526.91 | Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Radio navigational aid apparatus |
| 8529.10 | Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528; Aerials and aerial reflectors of all kinds; parts suitable for use therewith |
| 8529.90 | Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528: Other |
| 8532.21 | Other fixed capacitors: tantalum capacitors |
| 8532.24 | Other fixed capacitors: Ceramic dielectric, multilayer |
| 8536.69 | Coaxial connectors; cylindrical multicontact connectors; rack and panel connectors; printed circuit connectors; ribbon or flat cable connectors; other |
| 8536.90 | Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits: Other apparatus |
| 8541.10 | Diodes, other than photosensitive or light-emitting diodes (LED) |
| 8541.21 | Transistors, other than photosensitive, with a dissipation rate of less than 1 W |
| 8541.29 | Transistors, other than photosensitive, not elsewhere specified |
| 8541.30 | Thyristors, diacs and triacs, other than photosensitive semiconductor devices |
| 8541.49 | Photosensitive semiconductor devices, excluding photovoltaic generators and cells |
| 8541.51 | Semiconductor-based converters |
| 8541.59 | Semiconductor devices not specified elsewhere |
| 8541.60 | Mounted piezoelectric crystals |
| 8542.31 | Electronic integrated circuits: Processors and controllers, whether or not combined with memories, converters, logic circuits, amplifiers, clock and timing circuits, or other circuits |
| 8542.32 | Electronic integrated circuits: Memory |
| 8542.33 | Electronic integrated circuits: Amplifiers |
| 8542.39 | Electronic integrated circuits: Other |
| 8548.00 | Electrical parts of machinery or apparatus not specified or included elsewhere in Chapter 85 |
| 8807.30 | Other parts of airplanes, helicopters, or unmanned aerial vehicles |
| 9013.10 | Optical sights for mounting on weapons; periscopes; telescopes designed for the manufacture of parts of machines, appliances, instruments, or apparatus specified in this chapter or Section XVI |
| 9013.80 | Other optical devices, appliances, and instruments not specified elsewhere |
| 9014.20 | Instruments and appliances for aeronautical or space navigation (other than compasses) |
| 9014.80 | Other navigational instruments and appliances |

# Huaxia Bank

Goods under EU sanctions, as well as related to:

- Energy industry
- Mining industry
- Chemical industry
- High technologies
- Electronic devices
- Media
- Machines with electronic components
# Zhejiang Mintai Commercial Bank

| Code | Description |
| 8542.31 | Electronic integrated circuits: Processors and controllers, whether or not combined with memories, converters, logic circuits, amplifiers, clock and timing circuits, or other circuits |
| 8542.32 | Electronic integrated circuits: Memory |
| 8542.33 | Electronic integrated circuits: Amplifiers |
| 8542.39 | Electronic integrated circuits: Other |
| 8571.62 | Electrical machines and equipment |
| 8526.91 | Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Radio navigational aid apparatus |
| 8532.21 | Other fixed capacitors: Tantalum capacitors |
| 8532.24 | Other fixed capacitors: Ceramic dielectric, multilayer |
| 8548.00 | Electrical parts of machinery or apparatus, not specified or included elsewhere in Chapter 85 |
| 8471.50 | Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units |
| 8504.40 | Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters |
| 8517.69 | Other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network |
| 8525.89 | Television cameras, digital cameras and video camera recorders |
| 8529.10 | Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528; Aerials and aerial reflectors of all kinds; parts suitable for use therewith |
| 8529.90 | Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528: Other |
| 8536.69 | Coaxial connectors; cylindrical multicontact connectors; rack and panel connectors; printed circuit connectors; ribbon or flat cable connectors; other |
| 8536.90 | Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits: Other apparatus |
| 8541.10 | Diodes, other than photosensitive or light-emitting diodes (LED) |
| 8541.21 | Transistors, other than photosensitive, with a dissipation rate of less than 1 W |
| 8541.29 | Transistors, other than photosensitive, not elsewhere specified |
| 8541.30 | Thyristors, diacs and triacs, other than photosensitive semiconductor devices |
| 8541.49 | Photosensitive semiconductor devices, excluding photovoltaic generators and cells |
| 8541.51 | Semiconductor-based converters |
| 8541.59 | Semiconductor devices not elsewhere specified |
| 8541.60 | Mounted piezoelectric crystals |
| 8482.10 | Ball bearings |
| 8482.20 | Tapered roller bearings, including cone and tapered roller assemblies |
| 8482.30 | Spherical roller bearings |
| 8482.50 | Other cylindrical roller bearings, including cage and roller assemblies |
| 8807.30 | Other parts of aircraft, helicopters or unmanned aerial vehicles |
| 9013.10 | Optical sights for fitting to arms; periscopes; telescopes designed for use as parts of machines, appliances, instruments or apparatus of this chapter or Section XVI |
| 9013.80 | Other optical devices, appliances and instruments, not elsewhere specified |
| 9014.20 | Instruments and appliances for aeronautical or space navigation (other than compasses) |
| 9014.80 | Other navigational instruments and appliances |
| 8471.80 | Units for automatic data processing machines, excluding processing units, input or output units, and storage units |
| 8468.10 | Hand-held gas torches |
| 8468.20 | Gas equipment and apparatus for soldering, brazing, welding, or surface tempering |
| 8468.40 | Welding or cutting machines |
| 8534.00 | Printed circuit boards |
| 8534.20 | PCBs, plastic-impregnated, non-flexible, having a base entirely of impregnated glass with 3 or more layers of conductive materials |
| 9027.50 | Instruments and apparatus for physical or chemical analysis using optical radiation (ultraviolet, visible, infrared), other |
| 9030.20 | Oscilloscopes and oscillographs, excluding those specifically designed for telecommunications |
| 9030.32 | Multimeters with recording device |
| 9030.39 | Instruments and apparatus for measuring or checking voltage, current, resistance, or power without recording device (excluding multimeters), other |
| 9030.82 | Instruments and apparatus for measuring or checking semiconductor wafers and devices |

# China Everbright Bank

Goods under EU sanctions

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## What it means for cross-border trade

For a company moving goods between China and Russia, the restriction is rarely absolute. Payments shift to smaller regional banks, to branches in border cities, or to third-country intermediaries and [payment agents](https://wiki.private.law/en/payment-agents-eu), each adding cost and fragility. Settling in [renminbi through CIPS](https://wiki.private.law/en/cny) rather than dollars helps at the margin, yet a Chinese bank still fears the reach of EO 14114 on a yuan payment, because the threat is to its correspondent network. Routine commercial flows, such as ordinary [payments to Chinese suppliers](https://wiki.private.law/en/worldfirst-china-supplier-payments), usually pass unless a flagged code appears on the invoice.

Documentation now decides outcomes. Banks ask for contracts, end-user details and the exact HS code before they release funds, and a single line item in a sensitive chapter can freeze the entire payment. Holding the account through a [company registered in China](https://wiki.private.law/en/company-china) does not remove the screening, because the commodity code, not the account holder, drives the decision.

The European Union runs a parallel track. Its 19th package in late 2025 added microelectronics, propellant chemicals and military-grade metals to dual-use controls, and the 20th package, adopted on 23 April 2026, extended export restrictions to entities in third countries that re-route controlled goods. The two regimes reinforce each other, since an item caught by the EU dual-use list usually sits on the U.S. priority list as well.

> 🧭 Before invoicing, check the six-digit HS code of every line item against the Common High Priority List. If it appears there, assume any Chinese bank may decline the payment, and arrange an alternative route in advance rather than after a rejection.

## Where this is heading

The secondary-sanctions framework remains fully in force in 2026, and Chinese and Turkish banks keep tightening rather than relaxing their screening. Enforcement has moved from blunt refusals toward selective, code-by-code filtering, so the workable channels keep narrowing and shifting. Any list of restricted goods is a snapshot useful for planning, never a substitute for confirming the current position with the bank.

> 🍓 What governs these payments is the U.S. dollar, more than Russian or Chinese law. As long as a Chinese bank values its dollar clearing above any single client, it will read the HS code on the invoice before it reads the contract.

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## Factual claims

- OFAC widened the net on 12 June 2024 by redefining Russia's military-industrial base to cover every person already designated under Executive Order 14024.
- The secondary-sanctions framework remains fully in force in 2026, and Chinese and Turkish banks keep tightening rather than relaxing their screening.