Dual-Use Goods UK 2026 – Export Controls and Licence Requirements

When exporting goods from the United Kingdom, most companies focus on customs documents, HS codes and duties. However, there is a category of goods that – regardless of customs value – requires special export licences due to their dual-use potential. Failure to comply with these rules is not an administrative offence but a serious criminal matter.

What Are Dual-Use Goods?

Definition and Scope

Dual-use goods are products, technology and software that can be used for both civilian and military purposes, or that could contribute to the proliferation of weapons of mass destruction. The term "dual-use" does not mean the goods are military – many everyday industrial products fall into this category.

Examples of dual-use goods:

• High-end electronics: high-performance integrated circuits, radio communication systems, signal interception equipment.
• Chemicals: selected chemical precursors, explosives, substances used in the production of chemical weapons.
• Composite materials: carbon fibres, ceramic materials, special alloys used in aerospace and defence.
• Software and technology: programmes with advanced cryptographic functions, encryption technology, network intrusion systems.
• Lasers: high-power lasers used in industry or research that may have military applications.
• Drones and UAVs: unmanned aerial vehicles with specified technical parameters.
• Aviation equipment: avionics, jet engines, navigation systems.

Legal Framework: ECJU and UK Strategic Export Controls

Export Control Joint Unit (ECJU)

ECJU (Export Control Joint Unit) is a UK government unit under the Department for Business and Trade (DBT) responsible for controlling exports of strategic goods, including dual-use items. ECJU:

• Issues export licences for controlled goods.
• Maintains the OGEL (Open General Export Licences) database.
• Assesses applications for Standard Individual Export Licences (SIEL).
• Works with customs authorities on compliance checks.

UK Strategic Export Controls List (USEC List)

After Brexit the UK maintained export controls based on the UK Strategic Export Controls List (USEC List), which is largely based on the EU Dual-Use Goods Control List (EU Regulation 2021/821) but is an adapted UK document. The list is divided into categories:

• ML (Military List): military equipment.
• PL (Precursor List): chemical weapons precursors.
• Dual-Use: civilian goods with military potential, divided into 10 categories (from 0 = nuclear materials, to 9 = aerospace and propulsion).

Types of UK Export Licences

Open General Export Licence (OGEL)

OGEL is a general licence that allows certain goods to be exported to specified destination countries without the need to submit an individual application. OGEL is publicly available on GOV.UK – you simply need to register in the SPIRE system and notify your use of a given OGEL.

OGEL conditions:

• The goods must be precisely described in the OGEL text.
• The destination country must be on the permitted list (usually NATO allies, EU, Australia, Japan).
• The exporter must keep records for a minimum of 4 years.

Standard Individual Export Licence (SIEL)

Where an OGEL does not cover the goods or the destination country, a SIEL (Standard Individual Export Licence) must be obtained. Applications are submitted through the SPIRE system (spire.trade.gov.uk):

1. Register in the SPIRE system.
2. Complete the application form (description of goods, destination country, end-user).
3. Attach supporting documentation: End-User Undertaking (EUU), technical specification of the goods, pro forma invoice.
4. ECJU assesses the application within 20 working days (approximately 4 weeks).

Note: exporting without the required licence or with an incorrect licence can result in the goods being seized by UK Border Force. Always check requirements before preparing export documents.

Penalties for Exporting Without a Licence

Criminal Penalties

Exporting controlled goods without the required licence is an offence under the Export Control Act 2002 and the Export Control Order 2008. Penalties:

• Imprisonment for up to 10 years in cases of knowing violation.
• Unlimited financial fine.
• Confiscation of goods and financial assets.
• Prohibition on conducting export activities.

Important: not only physical export is subject to controls. Transmitting technology (e.g. technical drawings) electronically or verbally to a foreign recipient may also require a licence (deemed export).

How to Check Whether Your Goods Require a Licence

OGEL Finder and Rating Tool

1. Check the ECCN number or technology code of your goods – usually provided by the manufacturer or determinable from the technical specification.
2. Use the OGEL Finder on GOV.UK to check whether there is an OGEL covering your goods and destination country.
3. If no OGEL is available – submit a SIEL application through the SPIRE system.
4. If in doubt, contact the ECJU Helpline: 020 7215 4594 or ecju.helpline@businessandtrade.gov.uk.

The Polish Side of Export

If you are exporting dual-use goods from Poland to the UK (not from the UK), EU rules apply – EU Regulation 2021/821 and its Polish implementation. The competent authority on the Polish side is the Ministry of Development and Technology. Once a Polish export licence is obtained, the customs declaration for the UK is standard.

Dual-Use Goods and Exports to Poland / EU

Exporting dual-use goods from the UK to Poland and other EU countries is possible, but after Brexit the UK and EU maintain separate control lists. Goods that before Brexit were exported within the EU without a licence may now require a licence on the UK side. Each case must be checked individually.

For Polish companies importing dual-use goods from the UK: EU rules on the import of controlled goods apply on the Polish side – the Ministry of Development and Technology may require additional permits.

Official Sources

• GOV.UK: Strategic export controls licensing
• GOV.UK: Open General Export Licences
• GOV.UK: UK Strategic Export Controls List

Frequently Asked Questions (FAQ)

How do I check whether my goods are dual-use and require a UK licence?

Check the technical documentation of the goods and consult the manufacturer about the ECCN (Export Control Classification Number) or its UK equivalent. Then search for that code in the UK Strategic Export Controls List available on GOV.UK. If the goods are on the list, use the OGEL Finder – if no suitable OGEL exists, a SIEL application to ECJU is required. If in doubt, call the ECJU Helpline: 020 7215 4594.

How long does it take to obtain a SIEL in the UK?

A Standard Individual Export Licence (SIEL) is assessed by ECJU within 20 working days from the date of submission of a complete application in the SPIRE system. An incomplete application (missing EUU, technical specification, or incorrect description of goods) may be rejected or delayed. In urgent cases an expedited SIEL application can be submitted – ECJU decides on acceptance individually.

What are the penalties for exporting dual-use goods from the UK without a licence?

Exporting controlled goods without the required licence is a criminal offence under the Export Control Act 2002. The maximum penalty is 10 years' imprisonment and an unlimited financial fine. This applies to exporters, customs brokers (who have not verified the requirements) and intermediaries alike. UK Border Force has the authority to seize a consignment without prior warning.