Russia's Government adopted Resolution N° 1958 on 29 November 2025, amending Resolution N° 313 of 9 March 2022 to add eight commodity positions to Appendix 3 — the list of dual-use goods banned for export to "unfriendly" states. The added items are specialty electro-optical and semiconductor materials: lithium niobate, zinc telluride, gadolinium-gallium garnet, gallium arsenide, gallium phosphide, unprocessed and processed quartz wafers/plates, and polished tellurium-oxide prisms. These materials are inputs to electro-optical components (modulators, acousto-optic devices, IR/laser optics) with both civil and military (guidance, imaging) applications. The measure took effect 1 December 2025 and runs through the underlying ban's 31 December 2027 expiry; it applies to all countries except Eurasian Economic Union member states.

Analyst notesShow

Mechanism

Resolution N° 1958 is a narrow-scope amendment to Russia's core dual-use export-control instrument, Resolution N° 313 (9 March 2022), which itself implements Presidential Decree N° 100 (8 March 2022) establishing the "unfriendly states" export-ban list. Rather than a standalone action, this is the latest in a running series of Appendix-3 list expansions (the register already carries the Nov-2025 precious-metals-scrap extension, Resolution N° 1947, filed under the same theme) — Moscow periodically widens the dual-use goods schedule as it identifies additional strategic-technology inputs still flowing out through commercial channels.

The eight added items are unusually specific and cluster around electro-optical device manufacturing: lithium niobate and gallium arsenide/phosphide are substrate/modulator materials for photonic and RF components; tellurium-oxide prisms and gadolinium-gallium garnet crystals are used in acousto-optic and magneto-optic devices (laser beam steering, isolators); quartz wafers are a generic optical/semiconductor substrate. GTA's framing ("advanced photonic and semiconductor materials") and RBC's framing ("components for optical systems") both point to the same underlying concern: these are precursor materials for guidance, imaging and sensing electro-optics that Russia's domestic industry cannot yet fully substitute and wants to stop leaking to buyers in the West via re-export or grey-channel routes.

Severity is set at 3 (moderate) rather than higher because the list addition is narrow (eight items) and defensive/protective in nature (an export ban Russia imposes on itself, not a supply-chain weapon aimed at importers) — consistent with how the precious-metals scrap ban in the same theme was rated.

Downstream implications

Narrows the set of legal channels for Western and allied buyers to source these

specialty crystal/wafer materials from Russian producers, likely accelerating existing substitution efforts (China, domestic Western crystal-growth capacity) that were already underway following 2022-25 sanctions.

Signals Russia is still actively auditing and tightening its own strategic-materials

export perimeter more than three years into the "unfriendly states" regime, rather than loosening it — consistent with the broader Russia counter-sanctions theme's pattern of incremental list expansion.

Given the small number of specialised producers globally for tellurium-oxide optics and

gadolinium-gallium garnet crystals, downstream effects are likely concentrated in a thin set of optics/laser-component supply chains rather than broad electronics markets.

Open questions

Full HS/TN VED code-level list and exact appendix text were not independently verified

against the official gazette (publication.pravo.gov.ru); the primary citation here is a customs-law database mirror (Alta-Soft) carrying the verbatim decree text and signatory (PM Mishustin) — official-gazette access was attempted but the portal was unreachable during research.

Whether any of the eight materials were previously importable to Russia's now-banned

destination countries in meaningful volumes (i.e., whether this is a real trade-flow disruption or a largely symbolic list-tidying exercise) is unconfirmed.

Sources

Primary: Alta-Soft — full text mirror of Resolution N° 1958 (29 Nov 2025), amending Resolution N° 313

Secondary: Global Trade Alert — Russia: Temporary ban on exports of certain advanced photonic and semiconductor materials · RBC — Government temporarily banned export of optical-system components

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Mechanism

Downstream implications

Narrows the set of legal channels for Western and allied buyers to source these

Signals Russia is still actively auditing and tightening its own strategic-materials

Given the small number of specialised producers globally for tellurium-oxide optics and

gadolinium-gallium garnet crystals, downstream effects are likely concentrated in a thin set of optics/laser-component supply chains rather than broad electronics markets.

Open questions

Full HS/TN VED code-level list and exact appendix text were not independently verified

Whether any of the eight materials were previously importable to Russia's now-banned

destination countries in meaningful volumes (i.e., whether this is a real trade-flow disruption or a largely symbolic list-tidying exercise) is unconfirmed.