Dual-use goods UK — export controls and dual-use export licence

What are dual-use goods — definition and examples

Dual-use goods are products, software, and technologies that have a civilian application but can also be used for military purposes, in connection with weapons of mass destruction, or in activities contrary to national and international security. The term "dual-use" refers precisely to this duality: the same product can serve a peaceful manufacturing purpose as well as military or strategic ends.

A classic example is encryption software: widely used in banking and communications, it can equally be employed by military forces to protect combat communications. Other examples of dual-use goods include:

Electronics and integrated circuits — high-performance processors used in computers but also in missile guidance systems
Lasers and optical sensors — used in industry and medicine but also in targeting and reconnaissance systems
Chemicals and precursors — used in pharmaceutical or pesticide production but potential components of chemical weapons
Biological pathogens and reagents — used in scientific research but capable of being used to produce biological weapons
Telecommunications technologies — encryptors, modulators, and signal-interception devices
Avionic and maritime systems — navigation and control systems that can be fitted to warships or combat drones
Nuclear materials and equipment — uranium enrichment devices and other components potentially used in weapons programmes

It is important to note that whether a given product is a controlled good is determined by its technical classification and parameters — not the exporter's intent. Even if the exporter plans exclusively civilian use, the licensing obligation follows from the characteristics of the goods themselves. Checking the classification against the UK Strategic Export Control List (SECL) is the exporter's responsibility.

Source: gov.uk — Export controls: dual-use items, software and technology.

UK dual-use control list — how to check whether a product requires a licence

Since Brexit, the United Kingdom has maintained its own export control list — the UK Strategic Export Control List (SECL) — administered by the ECJU (Export Control Joint Unit). Until 31 December 2020, the UK applied EU Regulation 428/2009 (as amended) on export controls for dual-use goods. Following EU exit, the UK transposed those rules into domestic law through the Export Control (Amendment) (EU Exit) Regulations 2019 and manages the list independently of the EU.

Goods on the UK SECL are divided into categories (numbered 0–9) by technical field:

Category 0 — nuclear materials, facilities, and equipment
Category 1 — advanced materials (including composites and special metals)
Category 2 — materials processing (machine tools, precision machinery)
Category 3 — electronics
Category 4 — computers and data processing
Category 5 — telecommunications and information security
Category 6 — sensors and lasers
Category 7 — avionics and navigation systems
Category 8 — marine technology
Category 9 — aerospace and propulsion

Each category is divided into sub-categories: E (equipment), S (software), T (technology). Military goods (ML — Military List entries) are subject to even more restrictive controls and a separate licensing regime.

How to check whether a product requires a licence — a practical process:

Identify the technical parameters of the product (specifications, performance, applications)
Search the UK Strategic Export Control List on gov.uk by category or technical description
Check whether the product's parameters exceed the control thresholds in the relevant control entry
Identify the destination country and check whether an OGEL covering those goods and that route is available
If in doubt, submit a Rating Enquiry to the ECJU through the SPIRE system

Manufacturers and exporters should maintain classification records for every product subject to controls. The absence of such records may be treated as evidence of a failure to exercise due diligence in any ECJU investigation.

Source: gov.uk — Export controls: dual-use items, software and technology.

Types of UK export licence — OGEL, SIEL, OIEL

The ECJU issues three main types of export licence for dual-use goods. The appropriate type depends on the nature of the goods, the destination country, and the frequency of export. Each type is described below with practical guidance.

OGEL — Open General Export Licence

An OGEL (Open General Export Licence) is an open licence that is generally available. It is not issued to individuals — the exporter registers as a user of a given OGEL and may use it without submitting a separate application each time. Registration is free and is done through the SPIRE system.

The ECJU issues many different OGELs — each covering specific goods exported to specified countries or groups of countries. The most important OGELs for dual-use goods include those for low-risk countries (including Poland as an EU/NATO member) and those for specific industrial sectors. The exporter must meet all conditions set out in the relevant OGEL — including due diligence obligations, record-keeping requirements, and end-user checks. If the exporter cannot meet the OGEL conditions, they must apply for a SIEL or OIEL.

SIEL — Standard Individual Export Licence

A SIEL (Standard Individual Export Licence) is an individual licence for a specific export transaction: defined goods to a defined consignee in a defined country. Applications are submitted electronically through the SPIRE system (System for Processing Import and Export Requests) operated by the ECJU/HMRC.

Processing time for a SIEL application is typically 20–30 working days from the date a complete application is received. Where the application requires consultation with other government departments (e.g. the Foreign, Commonwealth and Development Office), processing may take longer. A SIEL is required when:

The goods are not covered by any available OGEL
The destination country is excluded from the scope of an OGEL
The exporter cannot meet the OGEL conditions (e.g. due diligence requirements)
The goods are being exported to a country subject to sanctions or an embargo

A SIEL application generally requires an end-user undertaking (see the section below) together with detailed technical documentation for the product and a description of the transaction.

OIEL — Open Individual Export Licence

An OIEL (Open Individual Export Licence) is an open individual licence — issued to a specific exporter and covering multiple transactions for defined goods to a specified group of countries or consignees. An OIEL is suitable for companies that regularly export the same dual-use goods to established recipients and need operational flexibility without applying for a licence on every transaction. Applications for an OIEL are submitted through SPIRE, and processing times are generally longer than for a SIEL — the ECJU carries out a more detailed risk assessment. An OIEL is subject to conditions and may be revoked if those conditions are breached.

Source: gov.uk — Export controls: dual-use items (ECJU) | gov.uk — Export Control Joint Unit.

How to apply for a licence through SPIRE — step by step

SPIRE (System for Processing Import and Export Requests) is the ECJU/HMRC electronic system for submitting export licence applications, managing licences, and registering OGEL users. SPIRE is accessible at: spire.businessandtrade.gov.uk. The steps below describe a SIEL application as the most common type of licence.

Step 1 — Register on SPIRE

Before submitting a first application, the exporter (or their customs agent) must register their organisation on SPIRE. Registration requires providing company details, a Companies House number (where applicable), the details of the person responsible for export compliance, and acceptance of the system's terms of use. Registration is free.

Step 2 — Prepare the documentation

Before submitting a SIEL application, you will need to prepare:

A detailed technical description of the goods, including parameters and specifications
The control classification (entry number from the UK SECL)
Exporter and consignee details (the importer in the destination country)
End-user details (which may be the same as the importer)
A description of the intended end-use of the goods
An end-user undertaking signed by the end user
The value and quantity of the goods
The destination country and any transit routes (where applicable)

Step 3 — Submit the application through SPIRE

In the SPIRE system, select the licence type (SIEL), complete the electronic form, and attach the required documentation. The system automatically validates the completeness of the application. Once it has been correctly submitted, the exporter receives a reference number for the application.

Step 4 — ECJU review

The ECJU processes the application within typically 20–30 working days. During this period the ECJU may request additional information or clarification — the exporter is notified through SPIRE. For high-risk goods or sensitive destination countries, the ECJU consults the Foreign, Commonwealth and Development Office (FCDO) and other departments, which may extend the timeline.

Step 5 — Decision and use of the licence

If the application is approved, the licence is made available in SPIRE. The exporter must maintain a record of all transactions carried out under the licence and retain the documentation for a minimum of 4 years (ECJU requirement). A licence may be revoked if the exporter breaches its conditions or if the circumstances of the transaction change. A refusal is recorded — the exporter may appeal or submit a new application with supplementary information.

When carrying out the UK export procedure, the ECJU licence number must be entered in the CDS UK export declaration in the appropriate document field. The absence of a valid licence at the time of customs entry results in the consignment being held by HMRC.

Source: gov.uk — Export Control Joint Unit.

End-user undertaking — when it is required and what it contains

An end-user undertaking (EUU), also known as an end-user certificate (EUC), is a formal commitment by the end user of dual-use goods that they will not use them for prohibited purposes (including production of weapons of mass destruction or terrorist activities) or transfer them to unauthorised recipients or countries without the ECJU's consent.

When an EUU is required

The ECJU requires an end-user undertaking for the vast majority of SIEL applications for dual-use goods, and in particular where:

The goods fall into higher-risk categories (e.g. dual-use technologies in the chemical, biological, or nuclear fields)
The destination country is classified as a higher-risk country
The consignee is unknown to the ECJU or has no history of transactions with the UK
The goods may potentially be re-exported to sensitive countries
The value or quantity of the goods exceeds specified thresholds

For exports to Poland (an EU and NATO member), an EUU may not be required for all goods — however, the exporter is responsible for verifying the requirements for the specific control classification and the specific application.

What an end-user undertaking contains

A standard EUU signed by the end user includes:

Identifying details of the end user (company name, address, country, contact details)
Description of the goods and their technical parameters
A declaration of the intended end-use — a detailed description of how and where the goods will be used
A commitment not to use the goods in connection with weapons of mass destruction or illegal military activities
A commitment not to export or divert the goods without the prior written consent of the ECJU
Consent to inspection by the UK government or an authorised person to verify end-use
Signature of a person authorised to represent the end user

The EUU must be signed by the end user themselves — not by an intermediary, trading agent, or freight forwarder. The ECJU may refuse to issue a licence if it finds that the EUU was signed by the wrong person or contains imprecise information about the end-use.

Polish companies importing dual-use goods from the UK should be prepared for a request from the UK exporter to sign an EUU. Signing an EUU involves no fees — it is an official document in the exporter–importer relationship required by the ECJU. EUU templates are available on gov.uk.

When exporting controlled goods, a correctly completed commercial invoice for controlled goods containing a reference to the export licence is also required.

Source: gov.uk — Export controls: dual-use items (ECJU).

Sanctions and dual-use goods — Russia, Belarus, and other sanctioned countries

Export sanctions form an additional layer of control on top of the dual-use licensing system. Exports to countries subject to UK sanctions (e.g. Russia, Belarus, Iran, North Korea, Myanmar) are subject to additional and often absolute restrictions, even where the goods themselves would fall within the scope of an OGEL for other destinations.

UK sanctions against Russia and Belarus

Following Russia's invasion of Ukraine, the UK imposed wide-ranging export sanctions. Exporting a large number of goods to Russia and Belarus is prohibited or requires a special OFSI/ECJU licence — including many categories of dual-use goods that under normal circumstances could be exported to other destinations under an OGEL. The UK Russia (Sanctions) (EU Exit) Regulations 2019 (as amended) contain a detailed list of goods subject to export prohibitions to Russia and Belarus. Before any export to those countries — even of goods that appear non-controlled — you must check the current sanctions list at gov.uk/government/collections/uk-sanctions-regimes-under-the-sanctions-act.

Implications for Polish companies in the supply chain

Polish companies acting as trading intermediaries may find themselves in a situation where dual-use goods purchased from a UK exporter are subsequently re-exported to Russia or Belarus by another intermediary. Such indirect circumvention of sanctions (sanctions evasion) is a criminal offence both in the UK and in the EU. The ECJU and OFSI (Office of Financial Sanctions Implementation) actively monitor supply chains and work with counterparts in EU countries, including Poland. Signing an EUU commits the importer to not diverting the goods — a breach of this commitment incurs criminal liability.

Other high-risk countries

Beyond Russia and Belarus, exporting dual-use goods to the following countries requires particular caution and almost always a SIEL or will result in a licence refusal: Iran (UK Iran Sanctions Regulations), North Korea (UN/UK sanctions), Myanmar, Syria, Sudan, Cuba, and Venezuela (for specified categories of goods). Sanctions lists are updated regularly — the exporter is responsible for checking the current status before every export.

Regardless of the dual-use licence, the exporter must hold a valid EORI number for UK exports — without it, a valid export customs declaration cannot be submitted.

Source: gov.uk — Export controls: dual-use items | gov.uk — Export Control Joint Unit.

Summary of the current official rules

Dual-use goods exported from the UK are subject to ECJU (Export Control Joint Unit) controls under the UK Strategic Export Control List. Export without the required licence is a criminal offence carrying a penalty of up to 10 years' imprisonment. Available licence types are: OGEL (open, free to use, for standard goods to low-risk countries), SIEL (individual licence for a specific transaction, 20–30 working days via SPIRE), and OIEL (open individual licence for multiple transactions). An end-user undertaking (EUU) is required for the majority of SIEL applications and must be signed by the end user. Sanctions against Russia, Belarus, and other countries impose additional absolute restrictions on top of the dual-use licensing system. Polish companies importing dual-use goods from the UK may be asked by the UK exporter to sign an EUU. This article reflects the legal position as at 2026-06-06. Please contact a customs broker before taking any action.

FAQ — frequently asked questions

How do I check whether my product is a dual-use good requiring a UK export licence?

You need to check the UK Strategic Export Control List (SECL) — the control list maintained by the ECJU (Export Control Joint Unit), which is part of the Department for Business and Trade. The list is available at gov.uk/guidance/export-controls-dual-use-items-software-and-technology-goods-for-torture-and-radioactive-sources. Goods are grouped into categories (0–9) by type: electronics, computers, telecommunications, information security, sensors, lasers, avionics, marine, aerospace, propulsion, nuclear materials, chemicals, biology. If a product appears on the list, exporting it without a licence is illegal. If in doubt, you can submit a rating enquiry to the ECJU.

What is the difference between an OGEL and a SIEL when exporting dual-use goods from the UK?

An OGEL (Open General Export Licence) is an open licence — free to use and available for many standard dual-use goods exported to most countries. The exporter must register and comply with the conditions set out in the licence but does not submit an individual application. A SIEL (Standard Individual Export Licence) is an individual licence for specific goods to a specific destination. Applications are submitted through the SPIRE system and processing typically takes 20–30 working days. A SIEL is required when the goods or the destination country are not covered by any available OGEL. Source: gov.uk/guidance/export-controls-dual-use-items-software-and-technology-goods-for-torture-and-radioactive-sources.

What is an end-user undertaking and when is it required?

An end-user undertaking (EUU) is a commitment by the end user of the goods that they will not use them for prohibited purposes or divert them to an unauthorised recipient. The ECJU requires an EUU for the majority of SIEL applications for dual-use goods. The document must be signed by the end user (not a trading intermediary) and must specify the intended use of the goods and a commitment not to transfer them without the ECJU's consent. EUU templates are available on gov.uk. Source: gov.uk/guidance/export-controls-dual-use-items-software-and-technology-goods-for-torture-and-radioactive-sources.

Does exporting dual-use goods to Poland require a special UK licence?

Poland, as a member of the EU and NATO, is treated by the ECJU as a low-risk country for most dual-use goods. In practice, many standard dual-use goods exported from the UK to Poland may be covered by an appropriate OGEL (Open General Export Licence), removing the need to apply for a SIEL. However, you should always verify the specific goods and their classification against the UK Strategic Export Control List. Polish companies importing dual-use goods from the UK may be asked by the UK exporter to sign an end-user undertaking. Source: gov.uk/guidance/export-controls-dual-use-items-software-and-technology-goods-for-torture-and-radioactive-sources.

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

Exporting controlled goods without the required licence is a criminal offence in the UK under the Export Control Act 2002 and the Export Control Order 2008. Penalties include up to 10 years' imprisonment for individuals and an unlimited fine. Other consequences may include revocation of export privileges, seizure of goods, and administrative sanctions. HMRC and the ECJU conduct regular investigations and work with international partners to detect illegal transfers. Source: gov.uk/guidance/export-controls-dual-use-items-software-and-technology-goods-for-torture-and-radioactive-sources.

Official sources

Export controls: dual-use items, software and technology, goods for torture and radioactive sources — GOV.UK
Export Control Joint Unit (ECJU) — GOV.UK

easyclearance.pl