Mr. Sanctions

Category: Open General Export Licences (OGEL)

  • September 10, 2026: ECJU updates OGL, adds OGEL for defence exports

    ECJU - BIST final

    New and updated ECJU General Licences for defence export collaboration

    The Export Control Joint Unit (ECJU) has updated the Open General Licence (Global Combat Air Programme) and introduced a new Open General Export Licence (Agreement on Defence Export Controls ‘De-Minimis’ Exports).

    These measures support defence collaboration with close international partners by providing simplified licensing arrangements while maintaining the UK’s robust export controls. Details on the new measures can be found in the Notice to Exporters linked below. 

    The following are now available on GOV.UK:

    Contact ECJU for queries about strategic export licensing via email at exportcontrol.help@businessandtrade.gov.uk 

    Here’s the Notice to Exporters:

    Notice

    NTE 2026/19: Updated OGL (Global Combat Air Programme) and new OGEL: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    Published 9 September 2026

    Introduction

    The Export Control Joint Unit (ECJU) has updated the existing GCAP Open General Licence and introduced a new Open General Export Licence for the Defence Export Controls Agreement.

    Both measures aim to support defence collaboration with close partners and provide simplified licensing arrangements, while maintaining the UK’s robust export controls.

    Exporters should review the relevant licence carefully and ensure that they can comply with all applicable terms and conditions before using it. Where the conditions of either licence cannot be met, exporters may use an alternative licensing route.

    Updated Open General Licence (Global Combat Air Programme)

    The Global Combat Air Programme (GCAP) is a joint programme between the UK, Japan and Italy to develop a next-generation combat aircraft.

    The previous GCAP Open General Licence (OGL), first published in August 2024, has been updated to reflect the programme’s progression into its next phase of development. The amendments:

    • add Supply Chain Nations
    • provide for authorised Observer Nation activities
    • update programme terminology

    Read the updated Open General Licence (Global Combat Air Programme)

    Subject to its conditions, the updated OGL permits the export and transfer of specified dual-use and military goods, software and technology to GCAP Partner Nations and GCAP Supply Chain Nations where those activities are necessary to support the development, production, test and evaluation, through-life support, use, disposal or decommissioning of GCAP. The licence also permits limited, authorised activities relating to Observer Nations.

    The previous GCAP OGL, dated August 2024, has been revoked and replaced by this updated licence. Existing registrations remain valid.

    Exporters should review the updated licence carefully and ensure they can comply with all the terms and conditions before using it.

    New Open General Export Licence: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    Read the new Open General Export Licence: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    This OGEL supports the UK’s implementation of the ‘de-minimis’ provisions contained in Article 3 of the Agreement on Defence Export Controls between the UK, France, Germany and Spain.

    The ‘de-minimis’ provisions apply where the value of UK-origin goods, software or technology does not exceed 20% of the total value of the final system into which they are to be integrated.

    The licence permits exports and transfers of specified military goods, software and technology to Partner Nations (France, Germany and Spain) for integration into a final system, where the total UK-origin content of that system does not exceed the ‘de-minimis’ threshold, and where that final system is to be transferred or exported from a Partner Nation to any destination not excluded by the licence.

    Exporters should review the licence carefully and ensure they can comply with all the terms and conditions before using it.

    Registration and guidance

    Before using these licences, exporters must register through SPIRE. This includes stating where you will keep records of the exports or transfers, and where ECJU may inspect them.

    Further information:

    Declaration requirements

    As outlined in Notice to exporters 2026/13, when exporters register to use OGELs or GEAs, they are given a unique licence reference in the following format: ‘GBOGE20XX/XXXXX’.

    For relevant exports, this code should be input into the UK’s Customs Declarations System (CDS), which includes a field where this licence reference can be entered.

    Including the licence reference on CDS will bring goods exports made under OGELs and GEAs into line with standard individual export licences (SIELs) and open individual export licence (OIELs). The roll-out of this requirement across all relevant OGELs aims to deliver data that will help us maintain the appropriate balance between transparency and administrative burden, while providing insight into OGEL usage and trends.

    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

    the updated Open General Licence (OGL):

    Open-General-Licence-Global-Combat-Air-ProgrammeDownload

    the new Open General Export Licence (OGEL):

    Open-General-Export-Licence-de-minimis-exports-treaty-on-defence-exportsDownload

    and the updated guidance:

    Guidance

    Guidance on Agreement on Defence Export Controls

    Updated 9 September 2026

    Overview

    This guidance provides background on the Agreement on Defence Export Controls and sets out the requirements for licence applications to be considered against Articles 1, 2 or 3 of the agreement.

    The Agreement on Defence Export Controls (the agreement) is a treaty between Germany, France, Spain, and the UK (the signatory states). The UK acceded to this agreement in December 2025. It aims to reduce the administrative burden for exports or transfers of defence related products and supports industrial partnerships between the signatory states.

    There are 3 key articles covering different aspects of co-operation under the agreement, which only applies to items on the Common Military List. There are only minor differences between the Common Military List and the UK Military List.

    Key articles of the agreement

    Article 1

    Article 1 covers defence exports related to joint intergovernmental programmes, between 2 or more signatory states, formalised through memoranda of understanding (MoUs) or intergovernmental agreements. Article 1 can apply to both new and existing programmes. In the UK, it will be the relevant Ministry of Defence (MOD) team who will confirm and identify programmes falling under Article 1.

    The principle of Article 1 is that a signatory state should not oppose an export or transfer to a third party, which is requested by another signatory state, other than in exceptional situations in which that transfer or export compromises its direct interests or national security. The agreement requires any concerns with any such export to be raised with the other contracting parties within 2 months.

    Article 2

    Article 2 facilitates exports and transfers arising from industrial co-operation projects that promote closer integration of defence industries across the signatory states.

    Article 2 establishes a 2-step process to facilitate exports and transfers between industrial partners involved in recognised co-operation projects. Its aim is to reduce the export control burden for defence-related products developed through collaborative efforts.

    Step 1: project recognition

    The first step is for the relevant signatory states to consider and agree that a specific industrial co-operation project qualifies under Article 2. This requires a coordinated submission of a project file by the industrial partners to their respective national authorities. In the UK, the MOD is responsible for assessing this project file and confirming project eligibility.

    Further advice on project recognition will be provided in due course.

    Step 2: export licensing

    Once a project is recognised, licence applications are assessed in accordance with Article 2. While Article 2 seeks to reduce the export licensing burden, it does not exempt exporters from submitting licence applications for transfers to industrial partners.

    The principle of Article 2 is that, in relation to a defence product developed by defence manufacturers in 2 or more signatory states, a signatory state shall not oppose the export or transfer by a manufacturer of another signatory state to a non-state party, other than in exceptional situations in which that transfer or export compromises its direct interests or national security.

    The agreement requires any concerns with any such export to be raised with the other contracting parties within 2 months from the date on being informed of the proposed transfer or export.

    Note, the decision to grant or refuse the licence for the export of the final product shall fall to the signatory state from whose territory that export is carried out. Those decisions do not fall within the scope of Article 2.

    Article 3

    Article 3 implements a de minimis principle which applies when the value of defence-related components from one or more signatory states in a final system exported by another signatory state is below 20%. It does not apply to exports covered by Articles 1 or 2.

    The de minimis principle applies when the value of defence-related components from one or more signatory states in a final system exported by another is less than 20% of the total value of that system. The final integrator will be responsible for assessing the overall contribution from each signatory state. They will take into consideration each of its direct suppliers representing over 2% of the total final value the products which that supplier procured directly from a contracting party concerned.

    Note, the total value excludes maintenance, spare parts, training, and repairs.

    Under the agreement, an end-user undertaking is not required to support an export licence application submitted for consideration under Article 3. Instead, a harmonised ‘Integration Certificate’ has been developed, which provides information on the goods and parties involved, end user details and a de minimis declaration on the value of defence-related products from a supplying signatory state to be integrated into the final system in another signatory state.

    While Article 3 applies to items on the Common Military List, certain goods are excluded from this principle, as listed in Annex 3 of the agreement. Detailed guidance on Article 3 is included in Annex 2 of the agreement. A worked example on the de minimis principle is provided within the guidance on completing the Integration Certificate.

    Open General Export Licence (OGEL)

    An Open General Export Licence (Agreement on Defence Export Controls: ‘De-Minimis’ Exports) has been published to support eligible exports under Article 3.

    This may remove the need for an individual licence application where the export is within scope and the exporter can comply with all the OGEL terms and conditions, including the Article 3 de minimis requirements.

    Where the OGEL does not apply, you should submit an individual licence application.

    Submitting licence applications for consideration under the agreement

    All applications submitted for consideration under the agreement will continue to be assessed in the usual way against the Strategic Export Licensing Criteria.

    Applications under Article 1: intergovernmental programmes

    When submitting licence applications for consideration under Article 1

    • the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT, for consideration under Article 1 of the Defence Exports Agreement’
    • if the ultimate end user(s) of the end products in a third country is known, they must be identified in the licence application

    Under the principles of Article 1, we will not normally refuse applications for export to a signatory state, apart from in an exceptional situation which compromises our direct interests or our national security.

    If we identify any such concerns, we will consult with other signatory states before making a final decision.

    Applications under Article 2: industrial co-operation

    When submitting licence applications for consideration under Article 2:

    • the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT, for consideration under Article 2 of the Defence Exports Agreement’
    • identify the ultimate end user if known
    • reference previous licences that enabled technology transfers under ‘previous applications’
    • clearly state the final products into which UK items will be integrated under ‘intended end use’
    • ensure all information aligns with the scope of the agreed project
    • attach the joint project descriptive file and confirmation of project eligibility

    Applications that are not properly marked or which do not contain the required information will not be considered under Article 2 and will be processed as a standard licence request.

    Under the principles of Article 2, we will not normally refuse applications for export to a signatory state, apart from in an exceptional situation which compromises our direct interests or our national security.

    If we identify any such concerns, we will consult with other signatory states before making a final decision.

    Exports of final products from an industrial co-operation project

    The decision to approve or refuse a licence to export the final product lies with the signatory state from whose territory the export takes place. This decision is outside the scope of Article 2.

    Export licence applications for export of a final product should not be marked for consideration under Article 2 and will not be assessed as such.

    However, the UK will notify authorities in the relevant signatory states if it refuses a licence for a system produced through recognised co-operation that includes components authorised for re-export by signatory states.

    To support this, UK exporters should identify, in the ‘intended end use of the products’ field in their licence application, that this application relates to a final product from an industrial co-operation project under Article 2 of the Defence Exports Agreement, and identify which signatory states were involved in the development of the final product.

    Licences relating to a recognised co-operation

    Certain exports or transfers – such as those involving technology, tools, or production line setup – may be necessary to implement co-operation but are not linked to a given export or transfer to a non-signatory state.

    To facilitate the processing of such licence applications, exporters should include the relevance to the agreed Article 2 industrial co-operation and the joint project descriptive file with the licence application.

    Applications under Article 3: de minimis principle

    Open General Export Licence (OGEL)

    For exports related to Article 3, exporters should first check whether the Open General Export Licence (Agreement on Defence Export Controls: ‘De-Minimis’ Exports) applies. If the OGEL applies, exporters must register to use it and comply with its terms and conditions.

    Individual Export Licence Applications

    Where the Open General Export Licence (Agreement on Defence Export Controls “De-Minimis” Exports) does not apply, exporters should submit an individual export licence application for consideration, for example standard individual export licences (SIELs).

    For the application to be considered under Article 3, the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT de minimis, for consideration under Article 3 of the Defence Exports Agreement’.

    If the application is not properly marked or contains the required information, it will not be considered against Article 3 and will be processed as a standard licence request.

    If the de minimis principle applies:

    • no end-user undertaking is required for exports to a signatory state
    • an integration certificate may be requested to confirm incorporation into the final system
    • we will assess the application without delay

    Under the principles of Article 3, we will not refuse applications apart from in an exceptional situation which compromises our direct interests or our national security. If the third-party recipient of the final system is unknown at the time of licensing, the signatory state exporting the system will be solely responsible for assessing that export once the recipient is identified.

    Applicants must ensure the following:

    • the proposed export is not listed in Annex 3 exclusions
    • the first recipients are in a signatory state to the agreement
    • the application concerns defence-related products that will be integrated into a final system in a signatory state and then remain in a signatory state or be exported from a signatory state to a non-signatory state

    The application must include supporting documentation specifying:

    • confirmation that the equipment is not excluded under Annex 3
    • the maximum value share of UK components (excluding maintenance, spare parts, training and repairs) in the final system, specifying whether it is below 20%
    • a description of the final system, including its Military List (ML) classification
    • identification of the first integrator and consignee (if known) responsible for exporting the final system
    • identification of the final consignee(s) of the integrated system
    • details of any items not covered by the de minimis rule

    Integration certificate

    Signatory states may request a certificate confirming integration of the product into the final system before transfer. Where a UK entity is the final integrator, they will need to complete the integration certificate. A template certificate is available on GOV.UK, for which there is separate guidance.

    Exports of final products from the UK

    The decision to approve or refuse a licence for exporting the final product lies with the signatory state from whose territory the export occurs. This decision is outside the scope of Article 3.

    English language version of the agreement

    View an English language version of the Agreement on Defence Export Controls.

    Guidance on completing the Integration Certificate

    View guidance on completing the Integration Certificate and a template of the certificate.

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  • Burning Question: is the new ECJU Dual-use OGEL unusual – or just not something we’re used to seeing?

    My prompt:

    Read today’s Notice to Exporters: https://www.gov.uk/government/publications/notice-to-exporters-202614-announcing-the-dual-use-ogel/nte-202614-announcing-the-dual-use-ogel . How unusual is using general licenses for dual-use goods? What alternatives do other major regulators (US, EU countries, Switzerland, Canada, Australia, Japan, etc.) use? Speak to me like I’m a professional but not an expert control expert.

    Claude responds:

    \What this notice actually does

    The UK has published a new Open General Export Licence (OGEL) for dual-use goods. The mechanism here is the key thing to understand: a general licence is a pre-published, standing authorization that any exporter can use once they register, rather than something you apply for shipment-by-shipment. This new licence makes it easier for UK businesses to export to trusted partners without applying for individual licences for each shipment.

    Two things stand out. First, it’s a consolidation — the new OGEL merges the EU member states Dual-Use OGEL and General Export Authorisation GEA001. Second, it expands coverage. Alongside destinations already covered by existing general licences (EU member states, the US, Japan, New Zealand, Australia, Canada), it adds South Korea, Singapore, Chile, Uruguay, and British Overseas Territories. The justification is notably data-driven: the additional destinations came from a review of historic licensing decisions showing these exports are consistently approved and present low risk, and the change could save exporters from applying for more than 500 individual licences each year.

    How unusual is this? Not at all — it’s the global norm

    Using general licences for dual-use goods is standard practice, not an exception. Essentially every major export-control regime runs a tiered system: individual licences for sensitive or risky transactions, and some form of general/bulk authorization for low-risk goods going to trusted destinations. The whole point is triage. The notice says this plainly: by channelling lower-risk exports to OGELs, the UK can focus expertise on the remainder where risks are highest.

    So the concept is unremarkable. What’s mildly noteworthy here is the breadth — pushing this many destinations into a single consolidated standing licence, and doing it on an explicitly data-led “we keep approving these anyway” basis. That’s a deregulatory, efficiency-driven move, but the underlying tool is conventional.

    What the other major regulators use

    The vocabulary differs by jurisdiction but the architecture is the same everywhere. Here’s the map:

    United States (BIS / EAR). The US doesn’t call them “general licences” — it uses License Exceptions. These are codified exceptions in the Export Administration Regulations that let you export without an individual licence if the item, destination, and end-use meet specified conditions. Relevant ones for dual-use trade among allies include STA (Strategic Trade Authorization, for close partners), GBS, and ENC (for encryption items). Same idea as an OGEL: pre-defined conditions, no case-by-case application.

    European Union. The EU runs General Export Authorisations (EUGEAs) under the Dual-Use Regulation (2021/821). The most important is EU001, which covers most dual-use items going to a list of trusted destinations (US, Canada, Japan, Australia, etc.). The UK’s “GEA001” lineage you see in this notice is literally a holdover from when the UK was inside that EU framework — it’s the same instrument, now domesticated. Individual EU member states (Germany’s BAFA, France, the Netherlands, etc.) also issue their own national general authorisations on top of the EU-wide ones.

    Switzerland. Uses Ordinary General Licences (OGL) and Extraordinary General Licences (EGL) under SECO, distinguishing destinations by trust level — same trusted-partner logic.

    Canada. Uses General Export Permits (GEPs), standing permits published by Global Affairs Canada for specified goods/destinations, alongside individual permits.

    Australia. Permits and the Australian Community concept under the Defence Trade Controls regime, plus general permissions; lower-risk trade with allies (notably under the AUKUS arrangements) is increasingly handled through broad authorizations rather than individual approvals.

    Japan. METI operates bulk/general licences (including a “Special General Bulk Export Licence” and similar instruments) for trusted destinations under its catch-all and list-control system.

    The pattern: named trusted-destination lists + standing authorizations + a registration or recordkeeping obligation + reserved individual licensing for sensitive cases. The UK notice fits this template exactly.

    The one genuine catch worth flagging

    “General” doesn’t mean “no compliance burden.” With OGELs and their equivalents, the obligation shifts from getting permission to proving you were entitled to use it. You have to register, confirm the goods and destination actually fall within scope, keep records, and be ready for inspection. The notice underlines this: you must register through SPIRE before using the licence, including stating where you’ll keep export records and where ECJU may inspect them. And the UK is now adding a new wrinkle — exporters get a unique licence reference that must be entered into the Customs Declarations System, bringing OGEL exports into line with the data captured on individual licences. That last part is a quiet tightening: more visibility into who’s using these standing licences and for what, even as the licences themselves get easier to use.

    So the short version: general licensing for dual-use goods is the universal default among serious regulators, the UK is simply consolidating and broadening its version, and the trade-off is that the paperwork moves from the front end (applying) to the back end (registering, classifying correctly, and documenting).

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  • Notice to Exporters 2026/14: a new way to control dual-use goods

    NTE 2026/14: announcing the Dual-Use OGEL

    Published 25 June 2026

    Introduction

    Export Control Joint Unit (ECJU) has published a new Open General Export Licence (OGEL), covering an extensive range of dual-use goods to a wider list of global destinations. As well as destinations covered by existing general licences for dual-use goods (including EU member states, the United States, Japan, New Zealand, Australia and Canada), this OGEL permits exports to South Korea, Singapore, Chile and Uruguay, and British Overseas Territories.

    The Dual-Use OGEL

    This new licence will make it easier for UK businesses to export to trusted partners, without the need to apply for individual licences for each shipment. Importers in new destinations will benefit from reduced delays and less administrative burden when sourcing goods from the UK.

    Covering items ranging from civilian aerospace components to academic research data, the licence will significantly facilitate trade and collaboration between key sectors across the globe.

    This licence replicates the conditions for 2 existing OGELs in a simplified format, while also expanding the destination scope.  

    The additional destinations on this licence have arisen from a data-led review of historic licensing decisions, which shows that these exports are consistently approved and present low risk. The inclusion of additional destinations in the OGEL coverage for dual-use goods could save exporters from having to apply for more than 500 individual licences each year. That review continues, and new destinations may be added to the scope of the Dual-Use OGEL in future.

    The UK maintains strict export controls, and all exports remain subject to robust legal and security safeguards. By channelling lower risk exports to OGELs, we can focus our expertise on the remainder, ensuring robust oversight where risks are highest.

    The new Dual-Use OGEL is a consolidation of the EU member states Dual-Use OGEL and the General Export Authorisation (GEA) GEA001. Exporters who are registered for those OGELs should register to use this OGEL moving forward.

    Before using this licence

    You must register through SPIRE, the online export licensing system before using this licence. This includes stating where you will keep records of the exports or transfers, and where ECJU may inspect them.

    Declaration requirements

    As outlined in Notice to exporters 2026/13, when exporters register to use OGELs or GEAs, they are given a unique licence reference in the following format: ‘GBOGE20XX/XXXXX’.

    For relevant exports, this code should be input into the UK’s Customs Declarations System (CDS), which includes a field where this licence reference can be entered.

    Including the licence reference on CDS will bring goods exports made under OGELs and GEAs into line with standard individual export licences (SIELs) and open individual export licence (OIELs). The roll-out of this requirement across all relevant OGELs aims to deliver data that will help us maintain the appropriate balance between transparency and administrative burden, while providing insight into OGEL usage and trends.

    Contact ECJU

    You can contact ECJU in the following ways.

    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

    and the OGEL:

    open-general-export-licence-export-of-dual-use-itemsDownload

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  • Notice to Exporters 2026/13: I do declare (on the UK’s customs declaration system)

    Export Control & Sanctions

    NTE 2026/13: declaring exports under OGELs and GEAs on the UK’s customs declarations system

    Published 13 May 2026

    Introduction

    When exporters register to use Open General Export Licences (OGELs) or General Export Authorisations (GEAs), they are given a unique licence reference in the form ‘GBOGE20XX/XXXXX’.

    The UK’s Customs Declarations System (CDS) includes a field, currently box 44, where this licence reference can be entered. Presently only a small number of OGELs have a condition that requires exporters to enter this field on CDS.

    We will be updating all relevant OGELs in the coming months to add a condition requiring the licence reference to be entered on CDS for all tangible exports. Including the licence reference on CDS will bring tangible exports made under OGELs and GEAsinto line with Standard Individual Export License (SIELs) and Open individual export licence (OIEL). The roll-out of this requirement across all relevant OGELs aims to deliver data that will help us to maintain the appropriate balance between transparency and administrative burden whilst providing insight into OGEL usage and trends.

    When this becomes a condition on relevant licences, the inclusion of the licences reference on CDS will be an enforcement matter for HM Revenue and Customs (HMRC). To ensure a smooth transition for OGEL users, export control joint unit (ECJU) are encouraging exporters to employ good practice by including their OGEL or GEA licence reference on CDS now.

    Using Freight Forwarders

    When using freight forwarders, exporters must provide the correct licence reference and an instruction to ensure the licence is correctly referenced in the Customs Declaration Service.  An incorrect declaration could constitute a criminal offence under Customs and Excise Management Act (CEMA) Article 167. The exporter of the goods and any agent concerned in the exportation or shipment may be considered responsible for the accuracy of a declaration.

    More information on using freight forwarders and customs agents can be found here.

    Updating information on CDS

    If the licence reference is missed or incorrectly added, a CDS entry can be amended at any time until cleared. If already cleared, exporters can complete a C1700 form and advise that a licence was omitted from the declaration, HMRC will then be able to amend the record to show licence usage.

    Record Keeping

    Each declaration on CDS generates an Export Entry Reference. Exporters must keep a record of this reference, or a copy of the entry with the other records they are required to keep for that export. Where exporters use freight forwarders to make a declaration on their behalf, they should request that the freight forwarder provide them with this refence number or a copy of the entry.

    Get customs data for import and export declarations – GOV.UK

    Where can you find the Licence Reference

    You can find the unique licence reference number by logging into your SPIRE account and checking the SPIRE letter that confirmed your registration. If you registered for multiple OGELs or GEAs at the same time the letter will contain a unique licence reference for each OGEL or GEA you registered for.

    OGELS with no registration requirements

    For certain OGELs, there is no requirement to register to use it meaning there will be no associated unique licence reference for exporters to enter into CDS. For these OGELs, a condition will be added requiring a reference relating to the OGEL name to be entered onto CDS. The required text will be set out in each OGEL. The OGELs with no registration requirements are:

    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

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  • April 27, 2026: ECJU nags you again about its survey

    Export Control & Sanctions

    Final reminder to have your say: Survey on Open General Export Licences

    The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items. This includes Open General Export Licences (OGELs), which are available for pre-determined military and dual-use controlled items being exported to a range of permitted restricted destinations.
    OGELs are often reported as a flexible and useful licence option, and can generally be used as soon as the exporter has registered. As such, ECJU is reviewing their usage and our overall service to exporters.
    If you are an exporter who has applied for an export licence from ECJU (whether or not you have registered for or regularly use OGELs), we would welcome your views to help shape our thinking.
    This week is your last chance to provide feedback via our short survey on:
    • exporter behaviour and experience in terms of using OGELs
    • why you do (or do not) use OGELs
    • what improvements to our service could be made to optimise their use

    The survey takes around 15 minutes to complete. Please note there is an opportunity to share contact details to allow us to follow up with you for further insights, but this is entirely optional and otherwise your survey responses will remain anonymous.

    Give your feedback via our survey hosted on Qualtrics.

    The closing date is 11:45pm on Thursday 30 April 2026.

    ECJU’s website can be found on GOV.UK

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  • Burning Questions: Export Control on both sides of the pond

    The Claude prompt:

    Explain the UK’s export control licensing system, and compare and contrast it to that of the US, in language suitable for non-expert professionals. Show your sources and verify that the response is supported by the sources. If anything is less than well-supported, see if you can find sources that buttress or clarifies those points.

    The response:

    UK and US Export Control Licensing Systems: A Plain-English Guide

    Export controls are laws that regulate what goods, technology, and services a country allows to leave its borders — and to whom. They exist to prevent sensitive or dangerous items from reaching hostile states, terrorist groups, or others who might misuse them. Both the UK and US have comprehensive systems, but they’re structured quite differently. Here’s how each works, followed by a direct comparison.

    Part 1: The UK System

    Who runs it?

    The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items. It brings together operational and policy expertise from the Department for Business and Trade (DBT), the Foreign, Commonwealth and Development Office (FCDO), and the Ministry of Defence (MOD). DBT has overall responsibility for the statutory and regulatory framework of export controls and for decisions to grant or refuse an export licence. FCDO and MOD are DBT’s principal advisers, advising on the Strategic Export Licensing Criteria used to assess licence applications.

    Think of the ECJU as a single front door for the whole system — but with three departments consulting behind the scenes before a decision is made.

    What items are controlled?

    The UK maintains the Strategic Export Control Lists, which detail military goods, dual-use items, and controlled technologies. These lists align broadly with EU and international lists but diverge in specific areas, particularly post-Brexit. The list is searchable online through the UK government website.

    Controlled goods include most items which have been specially designed or modified for military use and their components, including any technology and software used in or with the item, as well as dual-use items — goods that can be used for both commercial or military purposes, such as ball bearings that use technology which could be repurposed to make ballistic missiles.

    Importantly, even if a product is not listed on the control lists, it may be subject to end-use controls if the exporter knows or suspects it will be used in prohibited applications, such as weapons development or military purposes in embargoed countries. This “catch-all” provision imposes a responsibility on exporters to obtain licences for unlisted goods if they possess knowledge of restricted end-use.

    What types of licences are there?

    The UK offers three main licence types, designed to suit different export scenarios:

    1. Open General Export Licence (OGEL) — the simplest route. OGELs are the most flexible and commonly used licence, enabling unlimited exports to pre-approved destinations. You only need to register once to start using them. They’re pre-published, publicly available, and cover many routine, lower-risk situations.

    2. Standard Individual Export Licence (SIEL) — needed when no OGEL applies. SIELs for permanent exports are generally valid for 2 years or until the quantity specified has been exported, whichever occurs first. The ECJU aims to provide a decision on 70% of SIEL applications within 20 working days, and 99% within 60 working days.

    3. Open Individual Export Licence (OIEL) — for repeat business. An OIEL allows a named exporter to export multiple shipments of specific controlled goods to named destinations. It is tailored to an exporter’s specific needs and is available to exporters who have a track record in applying for export licences, or those who can demonstrate business need. OIELs are usually valid for 3 to 5 years.

    How are applications assessed?

    The ECJU assesses all licence applications on a case-by-case basis against the Strategic Export Licensing Criteria, which provide a thorough risk assessment framework. A licence will not be granted when it is inconsistent with the Criteria. Those criteria weigh factors including human rights in the destination country, regional stability, the risk of proliferation of weapons of mass destruction, and the UK’s international obligations.

    What are the consequences of non-compliance?

    It is a criminal offence to export controlled goods without the correct licence. Penalties vary depending on the nature of the offence. They can range from de-registration to fines or imprisonment.

    Part 2: The US System

    A more fragmented structure

    The US system is notably more complex because it is split across multiple agencies depending on the type of item involved. The three principal bodies are: the US Department of Commerce’s Bureau of Industry and Security (BIS), which oversees the Export Administration Regulations (EAR); the US Department of State’s Directorate of Defense Trade Controls (DDTC), which oversees the International Traffic in Arms Regulations (ITAR) and the Arms Export Control Act; and the US Department of Treasury’s Office of Foreign Assets Control (OFAC), which administers economic sanctions and embargoes. Nuclear-related export controls are additionally administered by the Nuclear Regulatory Commission and the Department of Energy.

    In practice, most exporters need to navigate two main regimes: ITAR and EAR.

    ITAR — for purely military items

    Administered by the US Department of State through the DDTC, ITAR governs items on the United States Munitions List (USML). This list covers a wide range of defense-related items, from firearms and explosives to spacecraft and advanced targeting systems. ITAR does not only apply to the physical objects themselves — it also applies to technical data and services related to those items. That means design documents, instructions, or even the know-how to maintain an ITAR-controlled aircraft engine are just as tightly regulated as the engine itself.

    ITAR regulations place strict restrictions on who can view or handle controlled items and data. In almost all cases, only US persons (meaning US citizens or permanent residents) are permitted access unless a special licence is obtained. Even something as simple as allowing a foreign national employee to view a controlled document on a shared drive could count as a violation if no authorisation is in place.

    EAR — for dual-use and commercial items

    The EAR regulates the manufacture, sale, distribution and export of commercial and dual-use items, technology and information not already covered by ITAR. The governing agency is the US Department of Commerce’s Bureau of Industry and Security (BIS), and its primary document is the Commerce Control List (CCL). Each item that falls under the EAR is assigned an Export Control Classification Number (ECCN).

    EAR applies to dual-use items — those with commercial applications that could also be adapted for military or security purposes, such as advanced semiconductors, encryption software, or certain chemicals. While EAR also places access restrictions, they are more nuanced. The level of restriction depends on the classification of the item, the destination country, the intended end use, and the end user.

    Penalties

    ITAR licences from DDTC typically take 60–90 days but can exceed 120 days for complex cases. EAR licences from BIS average 30–60 days. Civil penalties can exceed $1M per violation. Criminal penalties for wilful violations include fines up to $1M and 20 years imprisonment.

    Part 3: Comparing the Two Systems

    Here is where the most practically significant differences lie.

    1. Single agency vs. multiple agencies

    The UK channels everything through one body — the ECJU. The US divides responsibility between at least three major agencies (State, Commerce, Treasury), plus others for nuclear matters. The US regime has more jurisdictions, more categories of items, and more combinations of restrictions, exceptions, exemptions, and governing authorities. Overall the US regime is similar to but more restrictive and burdensome than the UK regime.

    2. The “deemed export” rule — a major US-specific concept

    This is one of the most significant differences for organisations employing international staff or collaborating across borders. The US export control regime recognises that certain disclosures or transfers of controlled items to certain individuals (typically foreign nationals that are not exempt) may be deemed to be an export or re-export. In plain terms: showing a controlled document to a foreign colleague in a US office can constitute an “export” requiring a licence.

    By contrast, the UK regime has no concept of “deemed” exports — disclosures and transfers under UK law are nationality-agnostic. The UK regime applies to transfers and disclosures of controlled items made from within the UK to destinations and recipients outside of the UK. This is a substantial practical difference for universities, research institutions, and multinationals.

    3. Extraterritorial reach — the US casts a much wider net

    US regulations routinely apply to items after they’ve been exported from the United States, and in many cases to items that have never touched US soil. For example, foreign-made products or software that contain US components, or are produced with the benefit of technology or software originating in the United States, may be subject to US export licence requirements.

    The US export control laws have a wide-ranging extraterritorial reach and the US government seeks to penalise companies and individuals who breach the export control laws, regardless of where they are located.

    The UK, by contrast, focuses primarily on exports departing from UK territory. EU and UK sanctions apply within the territory of the United Kingdom, aboard aircraft or vessels under their jurisdiction, to UK nationals, and to entities constituted under UK law. To date, neither the EU nor the UK has aggressively enforced sanctions against foreign persons processing transactions through their financial systems, in contrast to the United States.

    4. Licence types and flexibility

    The UK regime currently makes more extensive use of open licences and general authorisations (OGELs) for exporting predefined items to eligible destinations. These function as standing pre-approvals for common, lower-risk scenarios, reducing the burden on exporters. The US has analogous “licence exceptions” under the EAR, but commentators generally find them less accessible. Exporters with experience in both systems generally find the EU/UK system easier to navigate.

    5. End-use controls

    The UK regime has more widely defined end-use controls for unrated items — meaning UK exporters face a broader “catch-all” obligation to seek a licence even for items not on any formal list if they have reason to believe the end-use is problematic. The US end-use controls are similarly broad, though organised differently by item and destination.

    6. Shared international foundations

    Despite their differences, both systems rest on the same multilateral foundations — chiefly the Wassenaar Arrangement (conventional arms and dual-use), the Nuclear Suppliers Group, the Australia Group (chemical and biological), and the Missile Technology Control Regime. This means the categories of controlled goods are broadly similar; the differences are procedural, institutional, and in the breadth of jurisdiction.

    Summary Table

    FeatureUKUS
    Central bodySingle agency (ECJU)Multiple agencies (BIS, DDTC, OFAC, others)
    Main licencesOGEL, SIEL, OIELLicence exceptions (EAR), DDTC licences (ITAR)
    Military itemsUK Military List (via ECJU)USML / ITAR (via DDTC/State Dept)
    Dual-use itemsStrategic Export Control List (via ECJU)Commerce Control List / EAR (via BIS/Commerce)
    Deemed exportsNot applicable — nationality-agnosticYes — disclosures to foreign nationals in the US can require a licence
    Extraterritorial reachPrimarily territorialBroad — applies to US-origin content worldwide
    Ease of navigationGenerally simplerMore complex; multiple overlapping frameworks
    PenaltiesCriminal fines and imprisonmentCivil fines up to $1M+; criminal fines up to $1M and up to 20 years imprisonment

    Practical takeaway: If your organisation exports from the UK, you are dealing with one agency applying one set of criteria. If you work with US-origin technology or employ non-US nationals on US-controlled projects — even in the UK — US rules may apply to you regardless. Any organisation operating internationally should be aware that the two systems can overlap, and compliance with one does not guarantee compliance with the other.

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  • April 15, 2026: Your thoughts on Open General Export Licenses: a survey

    Export Control & Sanctions

    Invitation to respond to our survey on Open General Export Licences

    The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items. This includes Open General Export Licences (OGELs), which are available for pre-determined military and dual-use controlled items being exported to a range of permitted restricted destinations.

    OGELs are often reported as a flexible and useful licence option, and can generally be used as soon as the exporter has registered. As such, ECJU is reviewing their usage and our overall service to exporters.

    If you are an exporter who has applied for an export licence from ECJU (whether or not you have registered for or regularly use OGELs), we would welcome your views to help shape our thinking.

    Our short survey has been set up to get feedback on:
    • exporter behaviour and experience in terms of using OGELs
    • why you do (or do not) use OGELs
    • what improvements to our service could be made to optimise their use

    The survey takes around 15 minutes to complete. Please note there is an opportunity to share contact details to allow us to follow up with you for further insights, but this is entirely optional and otherwise your survey responses will remain anonymous.

    Give your feedback via our survey hosted on Qualtrics.

    The closing date is 11:45pm on Thursday 30 April 2026.

    ECJU’s website can be found on GOV.UK

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  • March 31 Sanctions-palooza: Notice to exporters 2026/09: change to the Open Individual Export Licence (OIEL) amendments process

    Notice

    NTE 2026/09: Change to the Open Individual Export Licence (OIEL) amendments process

    Published 30 March 2026

    Introduction

    The Export Control Joint Unit (ECJU) is changing the way it accepts amendment requests for Open Individual Export Licences (OIELs).

    When ECJU will accept amendment requests

    ECJU will accept amendment requests for OIELs in the following circumstances:

    • changes to exporter details (such as site or registered addresses)
    • amendments or additions to named recipient details for an existing destination (name and address)
    • requests to extend an extant OIEL, where a renewal application has already been submitted

    When ECJU will not accept amendment requests

    ECJU will no longer accept amendment requests for the following circumstances:

    • amendments or additions to goods
    • amendments or additions to destinations

    Reason for this change

    Processing substantive amendments to an Open Individual Export Licence (OIEL) takes as long as, or longer than, assessing a new licence application. This type of amendment is also not currently available on the LITE licensing system, which is used for online export licence applications.

    If you have any questions, please contact ecjulicensingunit@businessandtrade.gov.uk

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  • March 12, 2026: Notice to Exporters 2026/05 – Türkiye now permitted destination for Project Typhoon

    NTE 2026/05: update to open general export licence

    Published 11 March 2026

    Introduction

    The Export Control Joint Unit (ECJU) has updated the open general export licence (OGEL) military goods: collaborative project Typhoon has been updated to include Turkey as a permitted destination.

    An additional condition has been added to this OGEL requiring the licence reference in the form ‘GBOGE 20XX/XXXXX’ to be entered onto the UK’s customs declarations system.

    Registration requirements

    Exporters must ensure they are registered on SPIRE, ECJU’s export licensing system, for the updated OGELs. Existing registrations will carry over, but exporters should review conditions carefully.

    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

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