EU Sanctions DD WHAT.2: Product Documentation Consistency
What This Control Requires
Are product or service descriptions consistent, specific, and accurate across all documentation?
In Plain Language
Vague, generic, or inconsistent goods descriptions across invoices, shipping documents, and contracts are a documented EU red flag indicating potential misrepresentation to avoid sanctions controls.
The European Commission circumvention guidance provides detailed examples: items described as 'industrial equipment' without model numbers, different descriptions on shipping documents versus invoices for the same shipment, and documentation that does not match the actual contents when inspected.
This check is about ensuring that what you are selling is clearly described, consistently documented, and accurately represented - making it possible to verify that the transaction does not involve restricted goods.
How to Implement
Review invoices, purchase orders, shipping documents, and contracts for consistency. Product descriptions should be specific enough to enable classification against sanctions lists.
Red flags to check for: - Generic descriptions like 'industrial equipment' or 'electronic components' without model numbers, specifications, or technical parameters - Different descriptions on different documents for the same shipment (invoice says one thing, bill of lading says another) - Descriptions that do not match the Harmonised System (HS) or Combined Nomenclature (CN) codes used - Contents that do not match documentation when physically inspected - Deliberate vagueness that prevents sanctions classification
Implement a documentation review step in your order processing that verifies consistency across all trade documents. For each transaction, ensure that the product description, quantity, HS/CN code, and technical specifications are identical on the purchase order, commercial invoice, packing list, bill of lading, and any certificates of origin.
Train sales and logistics staff to use specific product descriptions and reject customer requests for vague or generic descriptions.
Evidence Your Auditor Will Request
- Documentation review process showing consistency checks across trade documents
- Sample verification records comparing descriptions across invoices, shipping docs, and contracts
- Training records for staff on specific product description requirements
- Records of any inconsistencies identified and how they were resolved
- HS/CN code accuracy verification for goods being shipped
Common Mistakes
- Using overly generic product descriptions that prevent sanctions classification
- Not cross-checking descriptions across different documents for the same transaction
- Allowing customers to dictate vague product descriptions on export documentation
- No systematic documentation review process - relying on ad hoc checks
- Ignoring mismatches between HS/CN codes and actual product descriptions
Related Controls Across Frameworks
| Framework | Control ID | Relationship |
|---|---|---|
| EU Sanctions DD | EU Sanctions DD WHAT.1 (related mapping) | Related |
| EU Sanctions DD | EU Sanctions DD WHAT.3 (related mapping) | Related |
| EU Sanctions DD | EU Sanctions DD WHY.4 (related mapping) | Related |
Frequently Asked Questions
Why would a customer request vague product descriptions?
What level of specificity is required in product descriptions?
Who is responsible for checking documentation consistency?
Track EU Sanctions DD compliance in one place
AuditFront helps you manage every EU Sanctions DD control, collect evidence, and stay audit-ready.
Start Free Assessment