Export Control survey
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You might still need an export licence even if your goods, technology or software are not listed on the UK Control Lists. This applies if the items will be transferred or disclosed to an end user who might use them for:
- Military purposes in a country subject to embargoes (Military End-use Controls);
- Weapons of Mass Destruction (WMD) purposes, namely for chemical, biological or nuclear weapons or other nuclear explosive devices or means for their delivery (WMD End-use Controls); or
- Human rights violations, e.g. torture and capital punishment (Human rights concerns).
Please review the guidance below to check whether any of these types of controls might apply to your activities.
Military End-use Controls
This category includes dual-use items not otherwise designated as controlled, where the exporter has been informed that those items are or may be intended for any of the following in an embargoed destination:
- incorporation into military equipment, or
- the development, production or maintenance of such equipment, or
- use in a plant for the production of such equipment
The countries currently subject to such embargoes are listed on the Government's website on trade sanctions, arms embargoes, and other trade restrictions. For example, it remains important to note that restrictions apply to exports to China and to Russia.
The same export controls apply to dual-use items that may be intended for use as parts of military goods that had been illegally exported from the UK, irrespective of their destination.
WMD End-use Controls
You must not export any items if you suspect, or have been informed, that those items might be used to make biological, chemical, or nuclear weapons of mass destruction, or their means of delivery, e.g. ballistic missiles or bombers and supporting systems and technology. It is important to note that WMD end-use controls can render transfers or disclosures made wholly within the UK as licensable transactions.
WMD end-use controls are considered by the ECJU in evaluating all export licence applications. If the ECJU has evidence or concern that the end user of the items might be connected to a WMD or ballistic missile programme, the relevant licence application will likely be refused.
WMD end-use controls also apply to:
- The brokering of controlled dual-use items intended for WMD purposes;
- Managing the transfer of software or technology for a WMD purpose within the UK, out of the UK or from outside of the UK to another country; and
- Providing technical assistance for a WMD purpose.
Human rights concerns
The UK Strategic Export Control Lists include the Human Rights List, which contains items that could be used to violate human rights, specifically in torture or capital punishment. Such items include among others:
- Chemicals that may be used to execute humans (amobarbital, pentobarbital, secobarbital, etc.);
- Irritating or incapacitating chemical agents (Pelargonic acid vanillylamide (PAVA), Oleoresin capsicum, etc.); or
- Items used to restrain humans.
Human rights considerations also feature in the ECJU’s evaluation of licence applications. This means that a licence might be refused due to evidence or concern that the end user is or may be implicated in human rights violations.
Cyber surveillance technology
Additionally, there is a regulatory trend towards stricter export controls on goods, technology and software that may facilitate violations of violate human rights, i.e. cyber surveillance and tracking technology. The US and the EU have introduced new export controls on such items. Any relevant changes to UK legislation will be reflected here in due course.