Every SKU in the catalogue passes through the same pipeline: export-control classification, sanctions screening, certification evidence, and supplier due diligence. This page documents the programme.
This page describes our compliance programme as of the “Last updated” date above. Specific processes, provider identities, and screening cadence are subject to change; for representations used in a purchase decision or RFP, request a signed compliance statement from anon.schneerson@gmail.com.
Every listed product carries an export-control classificationinitially submitted by the supplier and reviewed for plausibility and completeness by D27's compliance team. Classifications reference:
Displayed on every product card and product page: Unrestricted, EU-DU (EU dual-use), EAR, ITAR. Items flagged as controlled are blocked at checkout until a valid export-licence reference is provided and verified on file.
Catch-all controls. The EU Dual-Use Regulation contains catch-all provisions that extend controls to non-listed items intended for military end-uses in certain destinations (Art. 4) and to cyber-surveillance items that may be misused for internal repression or serious human-rights violations (Art. 5). Where D27 has knowledge or reasonable grounds to suspect a catch-all case, the order is paused and escalated to a compliance officer for licensing determination; buyers are required to notify D27 of any such end-use (see Terms §07).
Exporter of record. D27 operates a marketplace and is not the exporter of record. The exporter of record is the supplier or the buyer, as determined by the Incoterm on the order confirmation and applicable law. The parties are responsible for obtaining any export licence required for the transaction; D27 supports this process with classification data, end-use statements, and licence-reference capture, but does not assume the legal obligations of the exporter.
No reliance.Classifications displayed on the platform are provided for information only and do not substitute for the buyer's or supplier's own due diligence. Ultimate responsibility for export-compliance classification and licensing of a specific shipment rests with the exporter of record.
We run automated sanctions and restricted-party screening on every account and every order. Lists screened include, without limitation:
Screening extends to parties 50% or more owned (directly or indirectly) or otherwise controlled by a listed party (OFAC 50 Percent Rule; equivalent EU/UK ownership-and- control doctrine). Screening is performed on every account at onboarding, on every order at checkout, and on every change of registered ownership or address.
Screening lists are refreshed from the issuing authority at least daily under normal operations, and sanctions matches are re-run automatically on every new order. A match pauses the order and triggers mandatory human review by D27's compliance team; the buyer is notified of the hold. We do not override a match without documented grounds signed off by a compliance officer. Where an authority publishes an urgent listing, we apply the update on receipt.
Read-only status for your organisation is available at /account/compliance once signed in.
We track the following certifications per SKU and per supplier. Certifications originating in aerospace or defence contexts (AS9100, MIL-STD-810) are tracked where civilian products have been independently tested to those standards; their presence does not indicate a defence end-use:
Supplier-submitted certificate PDFs are stored in the supplier record, validated against the issuing body where technically feasible, and auto-attached to the order confirmation where applicable.
Before a supplier is activated on D27 we complete:
Suppliers enter into a written supplier agreement that (i) binds them to D27's export-control, sanctions, data-protection, and anti-bribery standards, (ii) requires immediate notification of material changes (ownership, certification lapse, list placement, regulatory action), and (iii) grants D27 the right, on reasonable notice, to audit compliance with those standards, whether by D27 personnel or an independent auditor bound by confidentiality.
Buyers cooperate with D27's compliance programme as set out in the Terms of Service §07 (Export Control & Sanctions).
Separate from regulatory classification, every SKU carries an EU-content percentage and a tier (Tier 1 ≥65%, Tier 2 50–64%, Tier 3 <50%), computed by value added per manufacturing step using supplier-submitted input data. This metric is provided for informational and sourcing-decision purposes only and does not constitute a determination of preferential or non-preferential origin under the Union Customs Code or any trade agreement; customs origin determinations must be made in accordance with the applicable rules of origin.
Detailed methodology: EU-content methodology.
If you believe a listing, supplier or transaction presents a compliance concern, contact anon.schneerson@gmail.com. Reports may be made confidentially, and pseudonymously where permitted by law. This channel is operated in accordance with the German Whistleblower Protection Act (Hinweisgeberschutzgesetz) for reports within its scope. We do not tolerate retaliation against good-faith reporters. External reporting channels to competent authorities remain available at all times.