21 Apr 2022

UK Export License – what goods need one and how to apply

MHA
UK Export License – what goods need one and how to apply

The controls may be in place for certain countries, regions or be for the type of goods (e.g. military weapons).

The lists cover products, software and technology.  It is the exporters responsibility to check the status of its goods to ensure that a rating is known prior to export. 

Due to the current situation in the Ukraine, this has highlighted the importance of companies being proactive in establishing the license status of their products.  Failure to have the correct license in place could result in severe penalties or even criminal proceedings.

This applies even if products are being exported to the EU, so this may not have been a consideration for UK businesses prior to Brexit and may have been missed.

If an exporter is not sure its products require an export license, then our team can assist them with establishing the rating and any applications for an individual license.  This would be via referencing to the Control Lists and contact with the Export Control Organisation (ECO). This may require registration for the ECO’s licensing system, SPIRE

The UK Consolidated List of Strategic Military and Dual-Use Items that Require Export Authorisation provides the consolidated listing which can be used to identify if your products fall under one of the licencing regulations.

For example:

Product Control List text Applicable Rating
Carbon
Fibre preforms

1C010e

1. Having any of the following:

  1. Inorganic "fibrous or filamentary materials" specified in 1C010.c.; or
  2. Organic or carbon "fibrous or filamentary materials", having all of the following:

1. "Specific modulus" exceeding 10.15 x 106 m; and
2. "Specific tensile strength" exceeding 17.7 x 104 m; and

 
Carbon
Fibre preforms

2. Having any of the following:

  1. Resin or pitch, specified in 1C008 or 1C009.b.;
  2. 'Dynamic Mechanical Analysis glass transition temperature (DMA Tg)' equal to or exceeding 453 K (180ºC) and having a phenolic resin; or
  3. 'Dynamic Mechanical Analysis glass transition temperature (DMA Tg)' equal to or exceeding 505 K (232ºC) and having a resin or pitch, not specified in 1C008 or 1C009.b., and not being a phenolic resin;
Licence Required

Get in touch

The regulations and the lists are very complex, so if you suspect that your client may need to check the rating of its products, then get in touch with our Customs Team who will be able to advise you on the best course of action.

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