Screen your goods against the latest EU sanctions

Last updated: 11 July 2026

1. Definitions
2. “Service” means the ET CÆTERA web-based sanctions/export-control screening and decision-support tool made available at tradesanctions.eu, including its database, results, and reports.
3. “Business Client” means a Client that concludes and uses the Service in the course of its trade, business, craft or profession.
4. “Consumer” means a natural person acting outside their trade, business, craft or profession; “Consumer-Entrepreneur” means a natural person conducting sole-proprietorship activity who, under Polish law, benefits from consumer-type protection for a contract not of a professional character for them.
5. “Screening Inputs” means HS/CN codes and any other data you enter or upload.
6. “Restrictive Measures” means EU sanctions and export-control measures under the EU regulations listed in the Service from time to time, as amended.
7. Parties. These Terms are between ET CÆTERA ETC Marcin Łukowski, VAT ID: PL8212542282 (“ET CÆTERA”, “we”) and the business identified at registration (“Client”, “you”).
8. What this tool is. ET CÆTERA Sanctions & Trade Compliance’s “Tradesanctions.eu” (“the Tool”) is an automated screening aid. It compares the HS/CN codes and descriptions you provide against a compiled database of restrictive-measure annexes under selected EU sanctions regulations. Its results are indicative only and are intended to assist, not replace, your own compliance assessment. The Service provides compliance-adjacent information and decision support only.
9. Not legal advice. The Tool does not provide legal, regulatory, or professional advice, and using it creates no adviser–client relationship. Decisions about whether a transaction is permitted must be made by you, with advice from a qualified professional and, where appropriate, confirmation from the competent national authority. The Client remains solely responsible for its sanctions and export-control compliance.
10. No warranty; verify against the primary sources. The database is compiled from, and article texts and product descriptions are reproduced from, the official multilingual versions of the relevant EU legal acts. Nevertheless the Tool is provided “as is,” without warranty of accuracy, completeness, or currency. EU sanctions are amended frequently; the database may not reflect the latest changes, may not cover every regime or provision, and may contain errors. The only authoritative sources are the consolidated legal acts as published in the Official Journal of the European Union and the classification data in TARIC. Always verify results against those current sources before acting.
11. Results are indicative only. They are generated by comparing Screening Inputs against a compiled database of Restrictive Measures and may be incomplete, inexact, or out of date. Restrictive Measures change frequently.
12. Some matches are shown as possible matches that apply only if both the code and the goods description correspond to the legal text, and some rest on classifications proposed by the Service that are unofficial and pending verification.
13. A “no match” is not a clearance. The absence of a flagged restriction does not mean an item is unrestricted or that a transaction is permitted. Matching is performed at the HS heading level (and at more specific levels where available); an item may fall within a restriction that the Tool does not surface, or under measures the Tool does not cover.
14. Possible matches and unverified classifications. Some results are shown as possible matches that apply only if both the code and the goods description correspond to the legal text, and some are surfaced by description or by HS classifications proposed by the Tool that are unofficial. These require your independent review and confirmation; they must not be relied on as definitive.
15. Scope. The Tool addresses only EU restrictive measures on goods and technology (e.g. export, import, and transit prohibitions and related conditions) under the regimes it lists. It does not cover asset freezes or listed persons/entities, financial or services measures beyond those shown, measures of other jurisdictions (e.g. US, UK, UN or other national regimes), or any obligation outside the annexes screened.
16. Certain measures are defined not by HS/CN code but by the technical characteristics of the goods, in particular dual-use items (Reg. (EU) 2021/821) and goods listed in Annex VII to Reg. (EU) No 833/2014 and equivalent lists (e.g. Annex Va to Reg. (EU) No 765/2006). Where the Service flags such items it uses indicative correlation mappings that are not legally binding and not exhaustive.
17. For all matters in this clause the Client must verify results against the actual technical parameters of the product, with input from its engineers and/or product managers, before relying on them. It is possible that an item is objectively caught even though the Service did not flag it.
18. Registration; VAT verification. EU business Clients must provide a valid VAT identification number. Non-EU Clients may be granted access subject to a post-registration manual review; ET CÆTERA may suspend access pending that review.
19. One licence per user. Each account is for a single named user (one licence per user). Login credentials must not be shared; concurrent or shared use may result in termination.
20. Subscription, cancellation, payment, refunds; right of withdrawal. Access is sold on a subscription basis. Cancellation stops future renewals; fees already paid are non-refundable, and cancellation does not entitle the Client to a refund for the current period.
21. Business Clients. The Service is provided only to Clients acting in the course of their trade, business, craft or profession. Such Clients are not consumers and have no statutory right of withdrawal.
22. Consumers and sole traders with consumer rights. If, exceptionally, a Client qualifies as a consumer, or as a natural person conducting a sole proprietorship who is entitled to consumer-type protection under Polish law (przedsiębiorca na prawach konsumenta), that Client has a statutory 14-day right of withdrawal. By purchasing and requesting immediate access, the Client expressly requests that performance of the Service begin before the end of the 14-day withdrawal period and acknowledges that, once the Service has been fully performed, the right of withdrawal is lost; where the Client withdraws before full performance, the Client shall pay for the part of the Service performed up to withdrawal.
23. Eligibility; sanctions screening; refusal of service. The Service is not available to, and ET CÆTERA may refuse or suspend it for, any person or entity that is (a) designated under EU restrictive measures, or owned or controlled by, or acting on behalf of, such a designated person, or (b) established in, resident in, or paying from a jurisdiction ET CÆTERA does not serve for sanctions-risk reasons. Where a payment or registration is declined on these grounds, the Service is not provided and ET CÆTERA is not obliged to give reasons.
24. The platform may terminate the contract, including when the Client claims that use of the platform is strictly necessary for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy (Article 5n(5), Regulation 833/2014), or is strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State, or for the recognition or enforcement of a judgment or an arbitration award rendered in a Member State, provided that such provision of services is consistent with the objectives of this Regulation and of Council Regulation 269/2014 (Article 5n(6)). As explained in Recital 19 of Council Regulation (EU) 2022/1904, the prohibition of legal services does not apply to representation, advice, preparation of documents or verification of documents in the context of legal representation services.
25. Modification, suspension and discontinuation of the Service. ET CÆTERA may at any time, at its discretion, modify, update, suspend, or discontinue the Service or any part of it. It will give reasonable prior notice of a planned permanent discontinuation for convenience, and may act immediately where required by law (including sanctions), on breach of these Terms or the eligibility criteria, or to protect the security or integrity of the Service. ET CÆTERA is not liable for any modification, suspension, or discontinuation.
26. Force majeure. Neither party is liable for failure or delay caused by events beyond its reasonable control, including acts of God, war, civil unrest, labour action, failure of utilities or communications networks, and acts of public authorities. This expressly includes the enactment, amendment, or application of sanctions or other restrictive measures, or a change in law, that make provision of the Service to the Client wholly or partly unlawful, impracticable, or commercially unreasonable. ET CÆTERA may suspend or terminate performance without liability.
27. Language versions. This notice is provided in several languages for convenience; the English version prevails in case of divergence. Interface translations are provided for convenience only; where legal-act text is reproduced, the official language version published in the Official Journal prevails over any reproduction or translation shown here.
28. Your data. Codes and files you submit are processed within your browser session to produce results and are not retained by the Tool beyond that session. You are responsible for ensuring you are entitled to process any data you upload.
29. Data you submit; sensitive data. You are not encouraged to upload sensitive or commercially confidential data. The Tool needs only the HS/CN code to screen; you may omit or individually encrypt any other field (e.g. product name, SKU, customer identifiers) before uploading. Data you submit is processed within your session to produce results and is not retained by the Tool beyond the session. The only screening-related records kept on ET CÆTERA’s servers are (a) the number of items screened, retained for quota and billing purposes (never the codes, file contents or results themselves), and (b) any bare HS/CN codes the Client expressly adds to the optional Watchlist feature, which are used solely to notify the Client when newly added Restrictive Measures affect them and can be deleted by the Client at any time. Saved-progress files are generated locally and stored only on the Client’s own device. You confirm you are entitled to process any data you upload.
30. The Client warrants it is entitled to process and submit any data it uploads and will not upload personal data.
31. Intellectual property. ET CÆTERA and its licensors retain all rights in the Service, the database, and all content. Reproduced legal-act texts and official descriptions remain subject to their source rights. The Client acquires no rights except this licence.
32. The Client must not: (a) use the Service to facilitate or conceal a breach of Restrictive Measures; (b) use it in or for the benefit of a sanctioned jurisdiction or person; (c) resell, sublicense, or provide access to third parties except as permitted; (d) reverse-engineer, scrape, or bulk-extract the database; (e) upload unlawful, infringing, or malicious content; or (f) impair the security or integrity of the Service.
33. Term and termination. These Terms apply for the subscription term and any renewals. ET CÆTERA may terminate or suspend immediately or on the Client’s insolvency. On termination the licence ends and the Client must cease use.
34. Marketing; use of Client name and logo. The Client grants ET CÆTERA a non-exclusive, worldwide, royalty-free licence to use the Client’s name and logo to identify the Client as a user of the platform in ET CÆTERA’s marketing materials, including on its website’s client list, including after expiry or termination of the agreement (to reflect that the Client was a user during the relevant period).
35. Limitation of liability. To the fullest extent permitted by applicable law, ET CÆTERA accepts no liability for any loss, penalty, or damage arising from use of, or reliance on, the Tool or its results. Use of the Tool is entirely at your own risk, and full responsibility for sanctions and export-control compliance remains with you.
36. ET CÆTERA’s total aggregate liability under or in connection with these Terms is limited to the fees paid by the Client in the 1 month preceding the event giving rise to the claim.
37. Indemnity. The Client shall indemnify and hold ET CÆTERA harmless against claims, losses, penalties, and reasonable costs arising from the Client’s breach of these Terms, misuse of the Service, breach of Restrictive Measures, or infringement of third-party rights.
38. Data protection. Each party will comply with the GDPR and applicable data-protection law. ET CÆTERA’s processing of personal data is described in its Privacy Policy. The Client must not submit personal data via Screening Inputs.
39. Governing law and disputes. These Terms are governed by Polish law. Any dispute arising out of or in connection with these Terms shall be finally settled by arbitration at the Court of Arbitration at the Polish Chamber of Commerce (SA KIG) in Warsaw, in accordance with its Rules.
40. Entire agreement; changes. These Terms (with the Privacy Policy) are the entire agreement. ET CÆTERA may amend these Terms on reasonable notice; continued use after the effective date constitutes acceptance.
41. Assignment. The Client may not assign without consent; ET CÆTERA may assign to an affiliate or successor.
42. Notices. Notices to contact@etcaetera-compliance.com.

The EU Trade Sanctions Tool (“the Tool”) is created to enhance access to information on restrictive measures applicable in the EU. The Tool aims to keep this information timely and accurate. If errors are brought to our attention, we will try to correct them. However, ET CÆTERA, as the administrator of the Tool, accepts no responsibility or liability whatsoever with regard to the information on the platform. The main purpose of the Tool is to screen HS/CN codes against restrictive measures in a fast, user-friendly and easily accessible way, so that the user can obtain general information on sanctions quickly and easily.

This information is not intended to be the basis for any decisions with legal implications. Only the legal acts published in the Official Journal of the European Union are authentic and produce legal effects. The information in the Tool is not necessarily comprehensive, complete, or up to date, but we intend to notify the user of this by indicating the date of the last legal update for a given sanctions regime, or by flagging a regime as being updated while data is being added.

ET CÆTERA has no control over linked external sites and does not assume responsibility for them.

If you need specific advice, you should always consult a suitably qualified professional.

Please note that the legal acts linked within the Tool are consolidated versions and are meant purely as a documentation aid. They have no legal effect. The Tool assumes no liability for the content of the consolidated legal acts. The authentic versions of the relevant acts, including their preambles, are those published in the Official Journal of the European Union and available in EUR-Lex. Those official texts are directly accessible through the links available in the consolidated documents.

It is our goal to minimise disruption caused by technical errors. However, some data or information in the Tool may have been created or structured in files or formats that are not error-free, and we cannot guarantee that the service will not be interrupted or otherwise affected by such problems. ET CÆTERA accepts no responsibility with regard to such problems incurred as a result of using this platform or any linked external sites.

Results produced by the Tool are indicative only and must always be verified against the official Regulation and the TARIC database. The Tool does not constitute legal advice and does not create any advisory or client relationship.

Last updated:

This policy explains how ET CÆTERA (“we”, “us”), the operator of the EU Trade Sanctions Tool (“the Tool”), processes personal data when you visit the site or use the platform. We are the data controller. For any privacy request, contact us at contact@etcaetera-compliance.com.

What we collect

Account & identity. When you sign in with Microsoft or Google, we receive your name, email address and a unique identifier from that provider. When you use an email-and-password account, we store your email and a securely hashed password. We do not receive or store your Microsoft or Google password.

Usage & screening. We record the number of screenings you run for quota and billing purposes. We do not keep a history of your screenings. The items, codes and regulations you screen are not stored against your account.

Billing. Payments are processed by Stripe. We do not see or store your full card details. Stripe handles them as an independent controller. We retain billing metadata (plan, subscription status, invoices) needed to run your subscription.

Technical. Like most services, our hosting provider processes basic technical data (such as IP address and request logs) to deliver and secure the service.

Why we process it & legal basis

We process your data to provide the Tool and your account (performance of a contract), to take payment (performance of a contract), to keep the service secure and prevent abuse (legitimate interests), and, where you have given consent, to understand usage so we can improve the Tool. You can withdraw consent for optional cookies at any time.

Who we share it with

We do not sell your personal data. We share it only with the processors that run the service: Microsoft Azure (hosting and database), Microsoft and Google (sign-in), Stripe (payments), and our email provider (Azure Communication Services) for transactional messages such as password resets. Each acts under appropriate data-processing terms.

International transfers

Our infrastructure is hosted in the European Union. Where a provider processes data outside the European Economic Area, that transfer is covered by an adequacy decision or appropriate safeguards such as the EU Standard Contractual Clauses.

How long we keep it

We keep account and billing data for as long as your account is active and as required to meet legal and accounting obligations. We do not retain a history of your screenings. You may request deletion of your account at any time.

Your rights

Subject to applicable law, you have the right to access, correct, delete, restrict or object to the processing of your personal data, and to data portability. You may also lodge a complaint with your local data protection authority. To exercise any of these rights, contact contact@etcaetera-compliance.com.

Cookies

We use essential cookies that are required to keep you signed in and run the platform; these cannot be switched off. With your consent we may also use optional cookies to understand how the Tool is used so we can improve it. You choose your preference in the cookie banner shown on your first visit, and can clear your browser storage at any time to be asked again.

Changes

We may update this policy from time to time. Material changes will be reflected by the “last updated” date above.