Export Controls and Other Countries

A licence may be required when importing controlled Items into the UK from anywhere in the world, including the European Union. Check with your supplier/collaborator whether an import licence is required and has been obtained before receiving the Items.

Controlled Items and the EU

Since Brexit, exporting Items to the EU is controlled in the same way as exporting Items outside the EU, a licence would be required for any Items on the control list. The UK government has issued Open General Export Licences (OGEL's) for many dual-use Items to be exported to the EU, which require registration to use that OGEL. If an OGEL isn't available a Standard Individual Export Licence (SIEL) would be required, which means an export can only take place after a licence is issued. Please complete the Export Control Query form if you intend to export Items to the EU and will require OGEL registration or application for a SIEL. 

US Export Controls

US export controls are extra-territorial in nature and hence apply here in the UK. Points to consider:

  • proactively enquire and identify whether US export controlled Items/Technology (Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR)) will be involved in the activity and transferred to you (especially where any activity involves a US entity). If so, ensure you are aware of the regulations regarding those Items/Technology.
  • Controlled US originated Goods/Technology could arrive indirectly via other countries.
  • Ensure you have assessed the access management, physical and information security measures around the controlled Items/Technology.
  • Be aware of re-exporting US controlled Items/Technology and the likely requirement they are also subject to UK Export Control legislation. 
  • Be aware a deemed re-export is when you transfer Items/Technology to a non-British person here at the University or in the UK who is not a permanent resident. US Export Controls not only apply to the destination country but to nationals of a specific country regardless of where they are. 

Items imported from China

On 1st December 2020 the Export Control Law took effect in China. There are a number of steps that need to be taken to administer this law and guidance on this is still unclear. However, it appears the Chinese Export Control Law is similar to the US and will apply extraterritorially. There could be conditions imposed on staff/students upon receiving China-controlled exports and it's likely there will be an increase in requests to complete end-use/user certifications/declarations. This will be updated when further information on this area is available. 

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