Military end-use controls

The guidance on the UK’s military end-use controls has been updated to provide more detail on the scope and application of the enhanced control, which was extended in 2022 to cover a wider range of exports to destinations subject to UK arms embargoes.

Building on the extensive exporter engagement ECJU has undertaken in recent months, this guidance now includes detail on types of exports that have been made subject to the enhanced military end-use control since 2022, updated case studies to help outline indicate whether the control would likely be applicable in different circumstances, and further considerations for businesses and research organisations. 

These updates are intended to help exporters better understand which items are commonly controlled due to end-use concerns and to anticipate and better meet potential compliance obligations.

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Guidance

Military end-use controls

When military end-use export controls apply and to which destinations.From:Export Control Joint Unit and Department for Business and TradePublished19 May 2022Last updated19 May 2026 — See all updatesGet emails about this page

Disclaimer

This guidance explains the operation of the military end-use controls set out in export control legislation. It does not constitute legal advice. If you are unsure about your obligations in any given case, you should consider taking independent legal advice.

Military end-use controls

The purpose of end-use controls is to allow export controls to be imposed, on a case-by-case basis, to goods, software and technology (referred to as ‘items’) which are not specified in the UK Strategic Export Control Lists. In practice, this means that even if the items which you intend to export do not usually require an export licence, you might still require one.

Circumstance 1: Where the purchasing country or country as of destination is an embargoed destination and the exporter has been informed in writing by the Export Control Joint Unit (ECJU), or is aware, that otherwise non-controlled items are or may be intended:

• for incorporation into military items listed in Schedule 2 (the UK military list) to the Export Control Order 2008
• for the use of production, test or analytical equipment and components therefor, for the development, production or maintenance of military items listed in Schedule 2 (the UK military list)
• for use in any unfinished products in a plant for the production of military items listed in Schedule 2 (the UK military list)

Circumstance 2: Where the exporter has been informed, or is aware, that otherwise non-controlled items are or may be intended for use as parts or components of military items listed in Schedule 2 (the UK military list) to the Export Control Order 2008, when those military items were originally exported without authorisation or in violation of an authorisation granted by the Secretary of State.

Circumstance 3: Where the exporter has been informed that otherwise non-controlled items are or may be intended for use by a ‘relevant entity’, which means:

• any military forces, para-military forces, police forces, security services or government intelligence organisations of an embargoed destination
• any person or entity involved in the procurement, research, development, production or use of items on behalf of these entities

Circumstance 3 is commonly referred to as the ‘enhanced military end-use control’.

The enhanced military end-use control does not apply to:

• the export of medical goods, including medicines and medical devices for the benefit of the civilian population of a country
• the export of consumer goods generally available to the public
• the transfer of software or technology generally available to the public

The enhanced military end-use control will also only be invoked, and a licence application refused, where it is assessed that the export would be capable of having a ‘relevant consequence’, within the meaning given to that term in the Schedule to the Export Control Act 2002.

Such consequences include, in summary:

• a threat to the UK’s national security
• having an adverse effect on peace, security or stability
• an act threatening international peace and security
• an act contravening the international law of armed conflict
• an act of internal repression
• an act that breaches human rights
• an act of carrying out (or of acts which facilitate) acts of terrorism or serious crime

End-use controls applicable to Weapons of Mass Destruction

Please note end-use controls also apply to weapons of mass destruction (WMD) related items and technical assistance. WMD end-use controls can be triggered in different ways to the military end-use control. You have an obligation under the export control legislation to notify ECJU if you are aware, have been informed by government, or suspect that your items are, or may be used for, WMD purposes.

Typical items which could be in scope

The enhanced military end-use control is not limited to specific technologies, capabilities or sectors, and can be used to control exports of any goods, software and technology as long as their end use could have a ‘relevant consequence’.

However, the most common types of items made subject to the enhanced military end-use control include (but are not limited to):

• aerospace and marine (including submersible) vehicle parts
• biotechnology, including engineering biology or synthetic biology
• materials analysis equipment
• quantum computing technology, including enabling technologies for quantum programmes (such as imaging cameras and cryogenic equipment)
• semiconductor design and manufacturing equipment
• telecommunications or advanced connectivity technologies

Note: This list is an indicative list based on licensing data since 2022 but is not exhaustive and may change over time.

Embargoed destinations

For the purposes of the military end-use controls, an ‘embargoed destination’ means a destination to which one or both of the following applies:

• it is subject to an arms embargo imposed by the United Nations Security Council or the Organisation for Security and Cooperation in Europe (OSCE)
• it is listed in Parts 1 or 2 of Schedule 4 to the Export Control Order 2008

As of May 2026, the embargoed destinations are:

• Belarus
• Central African Republic
• China (including Hong Kong and Macao)
• Democratic Republic of the Congo
• Democratic People’s Republic of Korea
• Haiti
• Iran
• Iraq
• Lebanon
• Libya
• Myanmar (Burma)
• Russia
• Somalia
• South Sudan
• Sudan
• Venezuela
• Zimbabwe

What you must do when you are informed of a licence requirement

You will be ‘informed’ that an export requires a licence under the military end-use control in writing. That letter will also set out the applicable legislation that makes the export licensable.

A decision to make the export licensable and subject to the controls will be based on an assessment of both the specific items and specific end-user.

The most common scenarios in which you may be informed an export licence is required are:

• having submitted an export licence application to ECJU, before you receive a final decision, you may receive an electronic letter via the licensing system advising you that a licence is required – this means that even if you withdraw the application, a licence is still required if you wish to later export the same items to the same end-user
• having presented goods for export, HMRC or Border Force detain the shipment for checks – if the detaining agency seek advice from ECJU, and we have concerns about the goods being used in an embargoed destination, you will receive a letter advising that an export licence is required, along with guidance on how to apply

Once you are informed that an export requires a licence, you must then apply for an export licence to proceed with that export. It is a criminal offence to attempt to export items without a licence if you have been informed of the need for a licence by ECJU.

End-User Advisory Service

The End-User Advisory Service (EUAS) on Spire enables exporters to seek advice on whether exports to named overseas entities could require a licence because of the WMD or military end-use concerns. This focuses on the end-user and does not consider the types of items being exported and for what purpose.

This advice is ‘non-statutory’ which means it does not constitute advice on how to follow the law and is no substitute for seeking your own independent legal advice. However, we recognise it is a helpful service to understand how export control rules might apply to complement exporters’ own due diligence.

For the purposes of military end – use controls, any advice given through EUAS should be treated as a recommendation. It is not the same as being informed that the controls apply and a licence is therefore required for export. As set out previously, if that is the case you will be clearly informed by ECJU separately. Nonetheless, advice from EUAS may be relevant as to whether you are aware the military end use controls might apply.

Apply for an export licence

Apply for a standard individual export licence (SIEL).

What you must do when you are aware of certain military end-uses 

If you are aware that your items are or may be intended for one or more of the end-uses specified in circumstances 1 or 2, you must contact ECJU who will advise on whether an export licence is required.

Additional due diligence and compliance guidance

It is the responsibility of the exporter to fully determine the extent of their specific risk exposure to military end-uses, including risk of diversion, and to develop an appropriate set of safeguards tailored to the organisation’s particular circumstances.

Staying up to date

It is therefore important to stay up to date with changes to the UK’s export controls, and to consider how any amendments affect your organisation’s compliance obligations. ECJU regularly provides these updates via notices to exporters. Visit the collection page to see previous notices and to sign up to receive the e-mail alerts.

Assessing end-users and risks of diversion

While there is no one size fits all approach, it is also important to consider risks of diversion and whether the ultimate end-user may be – or may be working on behalf of – the military, police or security forces of an embargoed destination before making arrangements for an export or transfer.

As well as using the EUAS, there are several steps your organisation can take when undertaking a risk assessment. This includes identifying potential red flag indicators of export controls evasion from open-source reporting and implementing an enhanced due diligence model to screen customers and business partners. In general, these practices could also be used to support subsequent licence applications. See guidance on compliance best practice and enhanced due diligence procedures for sanctions and export controls.

Compliance Code of Practice

The Compliance Code of Practice includes further guidance and advice on managing risks and ensuring compliance with export controls.

Licensing process

We assess all licence applications on a case-by-case basis against the Strategic Export Licensing Criteria. The Criteria provide a thorough risk assessment framework. We will not grant a licence when it is inconsistent with the criteria. Applications for countries subject to sanctions or embargoes are also considered against trade sanctions, arms embargoes, and other trade restrictions.

In reaching a decision on an application, the Department for Business and Trade receives advice from several departments, including the Ministry of Defence and the Foreign, Commonwealth and Development Office. Processing licences for sanctioned, embargoed or highly sensitive destinations is likely to take significantly longer than the standard 20 working day target.

See further information on the process and requirements for applying for a Standard Individual Export Licence.

Example scenarios where an export licence may be required

A. Exporting components for the repair or maintenance of military equipment to an embargoed destination:

The military end-use control applies to exports of non-listed dual-use items where the items are for incorporation of military items (listed in Schedule 2 of the Export Control Order) or for the development, production or maintenance of military items in an embargoed destination. These apply to any exporter whether they are a business or an academic institution, and whether the export consists of a physical export or a transfer of technology (information).

Example

Exporter A is approached to supply commercial spare parts and equipment to an embargoed destination in order to undertake repair of a military aircraft. Exporter A is aware that the items will be used for the repair of military equipment listed in the military list in an embargoed destination. Exporter A therefore has an obligation to contact the ECJU who will advise whether an export licence is required.

B. Exchanging research with a potential military application (upon being informed that a licence is required):

The military end-use control may apply to transfers of technology (information) even if the technology is not explicitly intended for a military programme. If your role in a collaborative research project involves sharing technology with organisations (such as universities) in embargoed destinations and those organisations also work on programmes which may have an end-use concern, the military end-use control may apply.

In this context, universities and research organisations should identify the risks that certain technologies pose to national security or human rights, as they may have applications in programmes of military concern, as well as civilian applications.

Example

Academic A works for a UK university and is collaborating on research with Academic B who works in an embargoed destination. Academic A exchanges (imports and exports) technology as part of their work.

The research is intended to underpin development of civil vehicle technologies for the consumer market. However, Academic B is also working on projects exploring military applications for emerging civil vehicle technologies and the technology being exchanged could be applied to military programmes.

The military end-use control would apply if Academic A has been informed that a UK export licence is required if it is assessed that the export of technology, in whole or in part, may be used to develop military capabilities of an embargoed destination.

C. Exporting equipment to a large organisation that undertakes many areas of work (upon being informed that a licence is required)

The military end-use control may apply to exports of equipment even if the intended end-use appears benign. If you are exporting equipment to an organisation that undertakes many different projects, such as a research organisation, and that organisation is supporting a programme of concern operated by the government or armed forces in an embargoed destination, then there may be a risk that the equipment may be used for purposes other than what is stated.

Example

Company A is exporting analytical equipment to a laboratory in a university in an embargoed destination. The laboratory declare that the equipment will be used by their project team to analyse new materials without a particular application, but the university is state-owned and equipment used by the laboratory is also available for use by other teams who undertake research and development (R&D) on behalf of the military.

The military end-use control would apply if Company A has been informed that a UK export licence is required if it is assessed that the equipment might be used by teams working on military R&D programmes.

D. Exporting items to a non-embargoed destination which could be diverted for use by an entity of concern in an embargoed destination

The military end-use control may apply to exports even if the exported items are intended for use in a non-embargoed destination. If you are exporting items, even on a temporary basis, that are at risk of being diverted and used by a ‘relevant entity’ (for example the military) of an embargoed destination, there may be a risk that the equipment may be used for hostile purposes within scope of the ‘relevant consequences’ in the Export Control Act 2002. It is important that your due diligence processes consider all potential end-uses and end-users, including the risk of diversion to an embargoed destination.

Example

Company A is exporting underwater survey equipment to a distributor based in a shipyard in a non-embargoed third country. The distributor has a trading partnership with the navy of an embargoed destination, and could install Company A’s survey equipment on board a vessel operated by the navy. The military end-use control would apply where Company A was informed that a UK export licence was required because it is assessed that the vessel is undertaking operations that are a threat to national security of the UK or allies because of its connection with an embargoed destination.

Further information

What to do if you are aware that the items are intended for a military end-use in an embargoed destination

If you are ‘aware’ that your items are or may be intended for one or more of the end-uses specified in circumstances 1 or 2, you must contact ECJU who will advise whether an export licence is required.

If you are aware (but have not yet been ‘informed’) that the items are or may be intended for use by a ‘relevant entity’ (as described in circumstance 3‘enhanced military end-use control’), you should engage with the ECJU’s end-user advisory service and consider applying for a licence. As part of this process ECJU will determine whether a licence is required for the export and will inform you of this requirement.

Typical types of end-users or end-uses to look out for

The military end-use control is not limited to specific technologies, capabilities or programme sectors.

The application of the control includes equipment with end-uses in many areas and the list of sectors is indicative of these cases.

The control applies to the 17 embargoed destinations, which since 2022 include China (including Hong Kong and Macao). More specifically, your organisation should consider where your otherwise non-controlled items are or may be intended for use by a “relevant entity”, which means: * any military forces, para-military forces, police forces, security services or government intelligence organisations of an embargoed destination * any person or entity involved in the procurement, research, development, production or use of items on behalf of these entities.

Considerations to minimise delays in an export licence application to make sure the process is an efficient as possible

To minimise delays on export licence applications and ensure the most efficient process, you must provide comprehensive and accurate documentation, specifically focusing on clearly defining the items (technical specifications, model numbers, intended design use), as well as the end-user and end-use. In short, providing as much information as you have on your goods, customer and their intended use and the supply chain can help our advisers.

Incomplete, inconsistent, or incorrect applications are a very common reason for delays, often resulting in requests for more information.

Considerations for how to manage customer expectations when waiting for a licensing application outcome

The government seeks to run a responsible export system, that enables UK growth whilst protecting national and global security. ECJU is very mindful of the commercial pressures on businesses, and the need to process licence applications with minimum delay. We strive to meet the public targets to conclude 70% of standard individual export licence applications within 20 working days and 99% within 60 working days.

Some destinations remain more challenging to assess and therefore take longer, particularly where geopolitical situations are complex. Licence applications under military end-use controls can sometimes take longer to assess than exports caught by the control list.

In general, we would also encourage exporters to review ECJU’s past processing performance in the licensing statistics we publish on a quarterly basis to help manage customer expectations.

As with all licence applications, ensuring that you submit accurate and complete applications will help avoid delays. Making amendments to live applications can substantially impact the time it takes ECJU to assess it.  See more information about how to apply for a licence here: Apply to export controlled goods.

Interaction with military end-use controls for universities when hosting visiting researchers or PhD students from embargoed destinations

First, consider how other national security risks and regulations apply. The Research Collaboration Advice Team (RCAT) – which is part of the Department for Science, Innovation and Technology, provide advice to research institutions on the national security risks linked to international research.

Generally, export controls do not apply to activity conducted wholly within the UK, except in specific cases where the WMD end-use control might apply.

However, controls – including military end-use controls – could apply to any material the researchers or students send overseas from the UK (including via email and other forms of intangible transfer), or which they take home at the end of their stay.

See guidance on how export controls can apply to the academic research from the UK.

Contact ECJU

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Email exportcontrol.help@businessandtrade.gov.uk

Telephone 020 7215 4594

Published 19 May 2022

Last updated 19 May 2026