UK Strategic Export Control Lists
The UK Strategic Export Control Lists form the basis of determining whether any products, software or technology that you intend to export are ‘controlled’ and therefore require an export licence.
The lists include reference to a wide range of items that could be used for military purposes, for torture or capital punishment or for the purposes of developing or manufacturing chemical, biological or nuclear weapons.
If your items are referenced on the Control Lists (ie listed under a Control List entry or ‘rating’) then you will need to apply for licence from the Export Control Organisation (ECO). The ECO is the UK Government’s regulatory authority for export licensing of strategic goods.
You should also note that if your goods are not listed on the UK Strategic Export Control Lists, that the ECO has the power to invoke ‘End-Use Controls’ if there are any specific concerns about military or weapons of mass destruction (WMD) end-use.
This guide will explain how the Control Lists are organised, how they are maintained and updated, and where you can seek further help and advice.
What are the UK Strategic Export Control Lists?
The UK Strategic Export Control Lists specify goods that need an export licence for ‘strategic’ purposes.
The lists comprise a number of separate item listings:
- UK Military List (Schedule 2 of the Export Control Order 2008)
- UK Dual-Use List (Schedule 3 of the Export Control Order 2008)
- European Union (EU) Human Rights List (Annexes II and III of 2005 EC Regulation 1236/2005)
- UK National Security and Paramilitary List (Article 9 of Export Control Order 2008)
- UK National Radioactive Sources List (Schedule referred to in Article 2 of Export of Radioactive Sources (Control) Order 2006)
- EU Dual-Use List (Annex I of the EU Dual-Use Regulation 428/2009)
- European Union General Export Authorisations (EU GEAs) (Annex II of the EU Dual-Use Regulation 428/2009 and Council Regulation (EC) No 1232/2011)
- Annex IV to EU Dual-Use Regulation 428/2009
How are the lists published?
These lists are published collectively as part of the UK Strategic Export Control Lists: Consolidated List of Strategic Military and Dual-Use Items.
The UK Military List is also published as a separate document.
Download the UK Consolidated List of Strategic Military and Dual-Use Items that Require Export Authorisation or download the UK Military List.
Both lists are updated on a regular basis. You should therefore double check that you are consulting the correct versions of the lists and be aware of when the lists are updated. To keep informed of amendments to the Control Lists, you should subscribe to the ECO’s Notices to Exporters.
Are my items listed on a Control List?
If you are unsure whether your items are listed, then you might find it helpful to read the guidance about strategic exports: when to request an export licence. This provides information about advisory tools provided by the ECO such as the Goods Checker database and the Control List Classification Service to help you in self-rating your goods.
If your goods are not listed on the Control Lists, you may still need a licence under End-Use Controls. This applies if the goods are likely to be sent to an end-user where there are concerns that they might be used in a WMD programme. For more details, see this guide on Military End-Use Control and Weapons of Mass Destruction (WMD) End-Use Control
How do I know whether my items are listed on a Control List?
The Control Lists comprise a wide range of items - some of which will be fairly obvious such as guns and ammunition (military items) and others which are less so, such as a wide variety of dual-use items. If your items are listed, then they will be referenced on the list under a Control List entry or ‘rating’.
If you are unsure if your items are controlled, you should read the guide on strategic exports: when to request an export licence. This specifically includes guidance on self-rating and how to identify your goods on the Control List.
What are ‘dual-use items’?
Dual-use Items are goods, software or technology (documents, diagrams etc) which can be used for both civil and military applications. They can range from raw materials to components to complete systems, eg aluminium alloys, bearings, or lasers. They could also be items used in the production or development of military goods or chemical, biological or nuclear weapons, eg machine tools, chemical/manufacturing equipment and computers.
How is the List organised?
Understanding how the list is structured should help you in identifying the correct ‘rating’. The List comprises several aspects:
- UK Military List (Schedule 2 of the Export Control Order 2008) - prohibited goods, software and technology (definitions), military, security and paramilitary goods, software and technology and arms, ammunition and related materiel - you can view the full text of the secondary export control legislation in the guide on the Export Control Order 2008
- UK Dual-Use List (Schedule 3 of the Export Control Order 2008) - specific prohibited dual-use goods, software and technology including explosive -related items
- EU Human Rights List (Annexes II and III of 2005 EC Regulation 1236/2005) - prohibited goods to non-EU member states, which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment - see also the guide on controls on torture goods
- UK National Security and Paramilitary List (Article 9 of Export Control Order 2008) - prohibited security and paramilitary goods to destinations in EU member states
- UK National Radioactive Sources List (Schedule referred to in Article 2 of Export of Radioactive Sources (Control) Order 2006) - prohibited radioactive sources - see the guide on controls on radioactive sources
EU Dual-Use List (Annex I of the EU Dual-Use Regulation 428/2009) - list of Dual-Use Items and technology prohibited from export to non-EU member states. It includes:
- Category 0 - Nuclear Materials, Facilities and Equipment
- Category 1 - Materials, Chemicals, Micro-organisms and Toxins
- Category 2 - Materials Processing
- Category 3 - Electronics
- Category 4 - Computers
- Category 5 - Telecommunications and Information Security
- Category 6 - Sensors and Lasers
- Category 7 - Navigation and Avionics
- Category 8 - Marine
- Category 9 - Aerospace and Propulsion
- For more details, see the guide on controls on dual-use goods (EU Dual-Use Regulation)
- EU GEAs (Annex II of the EU Dual-Use Regulation 428/2009 and Council Regulation (EC) No 1232/2011) - these are the EU equivalent of an Open General Export Licence (OGEL) - they authorise the export of specified dual-use items throughout the EU to specific non-EU destinations (for more details, including how to register for use, see the guide on European Union General Export Authorisations (EU GEAs))
- annex IV to EU Dual-Use Regulation 428/2009 - dual-use items requiring an export licence to all destinations, including those in an EU member state
Current version of the UK Military List
You can download the UK Military List
What is the UK Military List?
The UK Military List forms one element of the UK Strategic Export Control Lists, which incorporate controls on military items along with other controls on dual-use goods, torture goods and radioactive sources. You should check the wider Consolidated List if your items are likely to be included.
The UK Military List is also listed under Schedule 2 of the Export Control Order 2008, as amended. For more information and access to a full copy of the legislation see the guide on the Export Control Order 2008.
Amending orders are published in the guide on strategic export control legislation: amending orders and regulations.
How is the List organised?
If your items are listed, then they will be referenced under a Control List entry or ‘rating’.
The UK Military List comprises a range of ‘rating’ categories or entries. These range from category ML1 (smooth bore weapons) to category ML22 (technology). There are also some additional UK national controls classified under the codes ‘PL’.
How do I know whether my items are listed on the UK Military List?
If you are unsure if your items are controlled, you should read the guide on strategic exports: when to request an export licence. This specifically includes guidance on self-rating (ie identifying where your goods are referred to on the Control Lists, as well as details of tools and training sources to help you further.
The difference between the UK Trade Tariff and the UK Strategic Export Control Lists
It is an exporter’s responsibility to check whether your items require an export licence issued by the ECO, part of BIS. If you require a licence, you need to apply well in advance of shipment to avoid any potential problems (such as customs snagging at a port).
In doing this you should be aware of the differences between the UK Trade Tariff and the UK Strategic Export Control Lists.
The UK Trade Tariff is a three-volume guide that is designed to give exporters (and importers) information needed to dispatch and acquire goods traded worldwide and the rates of duty payable. The Tariff can be used in completing customs declarations.
Find commodity codes and other measures applying to imports and exports by accessing the online UK Trade Tariff tool.
However, in relation to classifying or ‘rating’ your goods for strategic export control purposes, the Tariff can only provide a broad indication of whether an export licence is required. For a clearer indication of whether your goods might need a licence you need to consult the UK Strategic Export Control Lists, explained below.
The Control Lists
It is very difficult to provide a more exact correlation within the Tariff since items might be controlled for many different reasons. The Tariff commodity headings are necessarily broad and do not account for original design intent (which is a key aspect of determining if an ECO issued licence is required).
If a particular tariff heading indicates that an export licence issued by the ECO is required, then in the first instance you should consult the UK Strategic Export Control Lists and determine if your items have a classification entry (also known as a ‘control list number’ or ‘rating’).
The Control Lists are documents published by the ECO. They detail items that are controlled (and therefore need a licence) for export. Items listed are either ‘dual-use’ or military items or other goods of concern such as radioactive sources or torture goods.
For further advice about ‘rating’ your items for export control purposes, see the guide about strategic exports: when to request an export licence.
Licence applications should be made electronically.
Where do the Control Lists originate?
Export Control legislation
The Control Lists are integral to the UK’s strategic export control legislation and should be read in conjunction with the appropriate articles and regulations. The legislation outlines how the Control Lists operate and are implemented. You can find out more in this overview of export control legislation. Details of amending orders are also published in the guide on strategic export control legislation: amending orders and regulations.
The UK Strategic Export Control Lists are derived from various international commitments - including foreign policy, national defence and security interests.
They are compiled mostly from the work of various international export control and non-proliferation groups or regimes. One of the main roles of these bodies is to decide what goods should be controlled to meet their counter proliferation objectives. Subsequently, the agreements are incorporated into national country legislation, including in the UK.
The international strategic export control regimes are:
- Australia Group (AG) - works to harmonise export weapons export control measures in order to limit unrestricted production of chemical weapons
- Chemical Weapons Convention (CWC) - bans the possession, development, stockpiling, transfer and use of chemical weapons and provides for the destruction of existing weapons and their means of production
- Missile Technology and Control Regime (MTCR) - a voluntary group of countries that share the goal of stopping the unmanned delivery of weapons of mass destruction
- Nuclear Suppliers Group (NSG) - responsible for making sure that nuclear export controls work (in practice)
- Wassenaar Arrangement - established with the goal of promoting transparency and increased responsibility in transfers of conventional arms and Dual-Use goods and technologies.
- Zangger Committee - draws up detailed lists of items on the nuclear control list
Updates to the Strategic Export Control Lists
Be aware of updates to the Control Lists
The UK Strategic Export Control Lists are periodically updated - mostly every half year. The updates reflect:
- new concerns (ie items added to the lists)
- changes to the scope of the controls
- small technical amendments
- de-control measures (ie items removed from the controls and for which a licence is no longer required)
You should therefore be careful to ensure that you are:
- aware of all recent updates to the lists
- check the latest list versions
- and take appropriate action to obtain a licence where necessary
No validity period for Control List status or ‘ratings’ advice
Whether or not you choose to self-rate or to seek advice from the ECO, you should be aware that there is no ‘rating’ validity period.
Past advice is out of date whenever the Control Lists change.
This does not mean that you need to request new advice every time the Control Lists change, since only specific parts of the list are updated. However, you should keep informed of changes and take appropriate action as a result.
How to keep informed
To remain updated of future Control List and legislative updates, you are recommended to subscribe to the ECO’s Notices to Exporters
Recent amendments to the Control Lists
A summary of all legislative amendments made to either the UK’s Export Control Order 2008 or the European Union’s Council Regulation 428/2009 (EU Dual-Use Regulation) and consequent changes to the UK Strategic Export Control Lists is published in the guide about strategic export control legislation: amending orders and regulations
These changes were also all announced in the ECO’s Notices to Exporters emails. The most recent relevant Notices about Control List changes relate to the following are also listed below:
- Amendments in force on 10 August 2012 made by the Export Control (Amendment) (No 2) Order 2012 (SI 2012 No 1910) which made a number of changes to both the UK Military List and the Consolidated List
- Amendments in force on 15 June 2012 which incorporates the changes made via the adoption of the European Union’s Council Regulation (EU) No 388/2012 which amends Annex I of the existing EU Dual-Use Regulation (Council Regulation 428/2009). Annex I is also referred to as the EU Dual-Use List
- Amendments in force in January 2012 as a result of amendments to the EU’s Torture Regulation (Council Regulation (EC) 1236/2005) which is amended by Commission Implementing Regulation (EU) No 1352/2011. This amendment introduces an EU-wide control on the export of certain drugs usable in execution by lethal injection (listed in Annex III of the Torture Regulation) and also amendments to the Annex II list of goods.
- Amendments in force on 30 November 2010 made by the Export Control (Amendment) (No 3) Order 2010 (SI 2010 No 2843) which placed controls on the export of Sodium Thiopental to the US.
- Amendments in force on 31 August 2010 made by Export Control (Amendment) (No 2) Order 2010 (SI 2010 No 2007) and announced in Notice to Exporters 2010/24
- Amendments in force on 27 January 2010 made by the Export Control (Amendment) Order 2010 (SI 2010/121) and announced in Notice to Exporters 2010/03
- Amendments in force on 16 June 2009 made by the Export Control (Amendment) Order 2009 (SI 2009/1305) and announced in Notice to Exporters 2009/15
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