Here’s Claude’s EU Practitioners Guide:
and its UK Guide:
Category: ECJU (UK)
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See what you think of the guides Claude assembled to European Union:
and United Kingdom sanctions:
Do you find these useful? Let me know in the comments…
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I decided to take a break from OFAC sanctions guides, so I asked Claude to evaluate the breadth, depth and sophistication of sanctions in the UK, EU, Switzerland, Singapore, New Zealand, Canada and Australia. It recommended that the EU and UK were most worthy, with Canada and Australia being the next tier of regulatory output.
So, now the Resources pages now have the following Practitioners and Plain Language guides for both the EU and UK:
- A thematic guide to how all the sanctions programs are organized, with overviews of each sanctions program, and
- A specialized guide for Russian sanctions
I will post the thematic guides, since they’re a different kind of animal from the others we’ve posted. If you want the Russia guides, well… click on that Resources page link and go get it, OK?
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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.
ECJU’s website can be found on GOV.UK
and here’s that guidance page (HTML only, sorry!):
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 2DYEmail exportcontrol.help@businessandtrade.gov.uk
Telephone 020 7215 4594
Published 19 May 2022
Last updated 19 May 2026
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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:
- Open general export licence (export after exhibition: dual-use items)
- Open general export licence (export after exhibition or demonstration: military goods)
- Open general export licence (historic military vehicles and artillery pieces)
Contact ECJU
General queries about strategic export licensing
Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DYEmail exportcontrol.help@businessandtrade.gov.uk
Telephone 020 7215 4594
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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 useThe 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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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
Feature UK US Central body Single agency (ECJU) Multiple agencies (BIS, DDTC, OFAC, others) Main licences OGEL, SIEL, OIEL Licence exceptions (EAR), DDTC licences (ITAR) Military items UK Military List (via ECJU) USML / ITAR (via DDTC/State Dept) Dual-use items Strategic Export Control List (via ECJU) Commerce Control List / EAR (via BIS/Commerce) Deemed exports Not applicable — nationality-agnostic Yes — disclosures to foreign nationals in the US can require a licence Extraterritorial reach Primarily territorial Broad — applies to US-origin content worldwide Ease of navigation Generally simpler More complex; multiple overlapping frameworks Penalties Criminal fines and imprisonment Civil 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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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 useThe 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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NTE 2026/11: expiry date for F680s on SPIRE
Updated 15 April 2026
Introduction
The Export Control Joint Unit (ECJU) of the Department for Business and Trade (DBT) is transitioning the MOD security approval form 680 (F680) away from SPIRE. From Friday 31 July 2026, you will no longer be able to process these applications on SPIRE.
We ask that you transition to using the ‘Apply to Export Controlled Goods’ service for your F680 applications.
Note that US UNCLASSIFIED ITAR applications are an exception to this transition and cannot be processed on the ‘Apply to Export Controlled Goods’ service at this time. If you submit US UNCLASSIFIED ITAR applications, you must continue to use SPIRE for these specific applications.
To prepare for the change, you must ensure you have an account with the new service. If you do not yet have an account, set up an account to export controlled goods.
Help and support
For further guidance, you can watch the ‘Apply for an F680’ video.
If you have any queries regarding your F680 application, contact spoecju-mod-lite-f680@mod.gov.uk.
If you need help with your account, contact the helpdesk via lite.support@businessandtrade.gov.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 2DYEmail exportcontrol.help@businessandtrade.gov.uk
Telephone 020 7215 4594
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Reminder: Upcoming Webinar: Editing Applications in the ‘Apply to Export Controlled Goods’ service (22 April)
Dear exporter,
This is a reminder to register for our upcoming webinar on Editing Applications in the ‘Apply to Export Controlled Goods’ service (also known as LITE). If you haven’t yet done so and would like to attend, please register using the link below:22 April 2026, 10:00-11:00: How to use the ‘Apply to Export Controlled Goods Service ‘: Editing Applications
You can pre-submit questions for the webinar series via this link: Export Control Joint Unit – Webinar Series – Fill in form
Those who register for the webinar will automatically receive the recording, so we encourage you to sign up even if you are unable to attend the live event.
If you have any questions, please submit them to
LITE.support@businessandtrade.gov.uk. We will endeavour to cover them in the webinar or respond separately.
Kind Regards,
Export Control Joint Unit