A. It is still possible the UK may exit the EU without a deal. As a consequence there will be changes for managing exports of controlled goods. Controlled goods are regulated through a system of export licensing and include military items, dual-use items (items with both civil and military uses), firearms, items that can be used for torture or capital punishment. The Export Control Joint Unit (ECJU) is responsible for the exporting control and licensing of these items.
Exporting military items to non-EU countries and EU
There will be no changes to controls on the export of military items from the UK, other than minor legislative fixes. You will need to continue to apply for licences as you do now.
Exporting dual-use items from the UK to the EU, and to the Channel Islands
The overall framework of controls for dual-use exports will not change, but there will be changes to some licensing requirements. You will need a new export licence if you are exporting dual-use items from the UK to the EU or the Channel Islands, issued by the UK. ECJU has published the Open General Export Licence (OGEL) for exports of dual-use items to EU countries. This licence also covers exports to the Channel Islands. This new export licence will remove the need for you to apply for individual licences and can be used immediately after the UK leaves the EU, following registration on SPIRE (the online export licensing system).
Exporting dual-use items from the UK to a non-EU country
The overall framework of controls for dual-use exports will not change, but there will be changes to some licensing requirements. If you already have a licence to export dual-use items to a non-EU country issued by the UK, it will remain valid for export from the UK. This includes registrations for Open General Export Licences and General Export Authorisations, which will still operate as UK licences. An export licence issued by one of the 27 EU countries will no longer be valid for export from the UK.
Exporting dual-use items from the EU to a non-EU country
You will need a new licence, issued by an EU member state, for exporting dual-use items from EU member states to a non-EU country. An export licence issued in the UK will no longer be valid to export dual-use items from an EU member state.
Exporting dual-use items from the EU to the UK
You will need a new licence, issued by an EU member state, for exporting dual-use items from EU member states to the UK. The European Council has proposed to add the UK as a permitted destination to Union General Export Authorisation (GEA) EU001, to minimise any additional licensing burden for those exporting dual-use items from the EU to the UK.
Exporting firearms from the UK to the EU
You will no longer be able to take personal firearms to the EU using the European Firearms Pass because this will no longer be available in the UK. The exemption that currently applies to the temporary export of firearms as personal effects to the rest of the world will now cover exports to the EU. If you want to take firearms as personal effects to an EU country, you will need to make sure that the destination country would also permit the import and re-export of the firearm. If you are a dealer or exporter of firearms, you will need to continue to apply for licences.
Exporting civil nuclear material
If you export civil nuclear material you can find out what other conditions will apply besides export controls. They include:
- civil nuclear regulation if there’s no Brexit deal
- nuclear research if there’s no Brexit deal
- Exporting goods that could be used for torture or capital punishment
- Strict controls apply to the export of goods that could be used for torture or capital punishment. The overall framework of the strict controls on these goods will not change, except that exports to EU countries will be treated in the same way as exports to non-EU destinations are treated now.
This means that you will:
- be prohibited from exporting items in annex II of Council Regulation 2019/125 to EU member states
- be prohibited from providing brokering, training or advertising services relating to items in annex II of Regulation 2019/125 to any person or entity in an EU member state
- need a licence to export items in annexes III and IV of Regulation 2019/125 to EU member states
In order to prepare, it is recommended you:
- check if you need an export licence for exports to EU countries on OGEL and goods checker tools, using as a guide the licensing provisions in current legislation for a ‘third country’ (a non-EU country) to understand what controls would apply for exports to EU countries
- refer to guidance links on OGEL and goods checker tools to apply for a licence
- remember, it’s your responsibility to comply with the export control regulations, and breaching export controls is a criminal offence
- Sign up for updates on export controls and licensing.