Accountability for research into Dutch microchips towards Russia

News hour

In recent months, the joint research editorial of the NOS and Nieuwsuur has investigated the trade flows of microchips made by Dutch companies to Russia. It shows that many millions have ended up in Russia since the invasion. In this article you can read how the editors work.

We have collected and analyzed trading data from various parties, some of which wish to remain anonymous. Part of the data was supplied by researchers from the British think tank RUSI. This is an independent military research institute that receives donations from, among others, the Dutch Ministry of Foreign Affairs and the British government.

The trade data available to the research editors almost certainly do not paint a complete picture. But the different datasets used together give a clear picture of the situation, experts confirm. The Dutch chip manufacturers Nexperia, Ampleon and NXP (the aforementioned Dutch companies) do not question the results. Their full response can be found in the box below.

Background conversations

In addition, (background) discussions were held with Dutch chip manufacturers, relevant officials, investigative services, researchers, experts and other parties involved. Where possible, they substantiated their information with (confidential) documents.

Talks were also held with a Latvian transporter, a Russian importer and a Chinese exporter. Insofar as they wanted to respond officially, this has been incorporated in the publications. The Dutch companies involved did not want to respond to camera. We asked them questions in writing, which they (partly) answered in writing. All these answers can be found in PDF form at the bottom of this page.

Which chips were subject to EU sanctions at what time? Since October, no chip is allowed to go to Russia. How things were before that is difficult to find out because countless types of chips are produced. It depends on specific qualities whether a semiconductor, which includes chips, is allowed for export. These rules have been revised several times in the past year. Only in a few cases did it become clear from the trade data exactly which chips were being exported. Customs could not give a definite answer to the question whether a specific chip that we submitted falls under the sanction rules.

The European Commission has stated in a response that it may be punishable if chips from the EU end up in Russia via third parties. For example, if an exporter in the EU should reasonably have known or found out that this could happen. “If the exporter in the EU knowingly fails in such due diligence, it can be considered sanction evasion.” The spokesperson also says that the European Commission “cannot respond to individual cases”.

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