Classification of goods against the export control lists is essentially a technical exercise.  However, there are a few basic ground rules that can apply to any export that a non-technical person can use.

 

In the Export Control world, there are only two types of items – Military and Dual Use.  A Military item is one that is designed or modified for a military application.  Clearly a battle tank is a military item but so is an electronic component if it was designed to the requirements of a military End User.  Almost all military items are subject to export control.

 

A Dual Use item is one that is designed for commercial applications but can then be used by commercial or Military End Users (hence two users or ‘Dual Use’).  The Dual Use Items control lists only controls a small fraction of Dual Use goods.  The List is based on technical parameters and usually controls the fastest, latest or highest technology items.

 

 

1. Is the item you are exporting designed or modified for a military use?
Virtually any item designed to a military specification will be subject to export control
If an item is modified for military use, it has an electrical, mechanical or structural that is designed for military use incorporated into it. For example a commercial Land Rover will be considered as a Military item if it has a 24V electrical system that was specified by the Military fitted to it.

 

 

2. If the item is not designed or modified for Military use, it will be considered as a Dual Use item.  For a Dual Use item to be controlled, it will need to have a utility in either conventional weapons or in Weapons of Mass destruction (e.g. Biological, Chemical, Nuclear weapons or Missiles to deliver them). The Dual Use list is broken in to 10 Categories which are listed below:

 

Category 0 Nuclear Materials, Facilities and Equipment
Category 1 Special Materials and Related Equipment
Category 2 Materials Processing
Category 3 Electronics
Category 4 Computers
Category 5 Telecomms (Part 1) and Information Security (Part 2)
Category 6 Sensors and Lasers
Category 7 Navigation and Avionics
Category 8 Marine
Category 9 Aerospace and Propulsion

 

For your item to be controlled, it must fit into one of the 10 Categories above.  You can see from this list that items such as Food or Commercial vehicles are not controlled.

 

 

3. The next step is to search the Lists to see if you can find your item.  The Lists will always describe an item generically and never by a brand name or part.  You will need to think about the most likely words that will describe your item and also any alternatives that may be used.  Keep thinking about the 10 Category structure – if you manufacture electronic components, your goods will almost certainly be controlled in Category 3.

 

The List has been designed where possible so that only one entry will cover an item.  Where there is ambiguity, there will be notes telling you where to look e.g. underwater optical fibre could be controlled under Category 5 part1 or Category 8.  Notes will tell you which Category to look in.    If you find an entry that relates to your item, you will need to compare its characteristics with those on the List.  If you meet or exceed the control parameters you will need an export licence.  If not, your goods are not listed.

 

 

4. There are some tools that can help your search.  If you go to the Export Control Organisation website, you can download a pdf document of the Control List from .

 

You can search the pdf, which covers all strategic export controls using the pdf facilities.

 


You could also use the Goods Checker.  The Goods Checker uses the same Control List as the pdf but displays it in a slightly different way.  It also adds reasons why the goods are controlled and ahs some pictures of licensable goods.  In addition to the Basic search mode, which is similar to the facilities of the pdf document, the Advanced Search mode allows for searching for multiple words.

 

 

 

 

 

 

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