Export Control (Dual-Use Technology)

UK export controls apply to any business exporting goods, software, technology, or providing technical assistance that could have military or weapons-related applications. Controls cover physical exports, electronic transfers (including email and cloud storage), and verbal disclosures to persons outside the UK.

If your goods, software, or technology appear on the UK Strategic Export Control Lists, you need a licence before exporting. Even if they are not listed, catch-all controls may apply if you know or suspect the items could be used for weapons of mass destruction or military purposes.

The Export Control Joint Unit (ECJU), part of the Department for Business, Innovation, Science and Trade, administers licensing. HMRC enforces at the border and prosecutes offences.

What is controlled

The UK Strategic Export Control Lists comprise:

• the UK Military List (Schedule 2 of the Export Control Order 2008), with 22 categories (ML1-ML22) covering military goods, software, and technology
• the UK Dual-Use List (Annex I of the assimilated Dual-Use Regulation), with 10 categories (0-9) covering goods usable for both civil and military purposes, based on the Wassenaar Arrangement
• UK national controls (Schedule 3), with additional UK-specific controls including on radioactive sources and emerging technologies

The dual-use categories are Nuclear materials (0), Special materials (1), Materials processing (2), Electronics (3), Computers (4), Telecommunications and information security (5), Sensors and lasers (6), Navigation and avionics (7), Marine (8), Aerospace and propulsion (9).

The lists are updated approximately twice per year. From November 2025, new '500 series' entries integrate emerging technology controls (quantum, cryogenic, semiconductor manufacturing) into the main dual-use framework.

Intangible transfers and cloud computing

Export controls apply equally to intangible technology transfers. You need a licence whether you transfer controlled technology by:

• electronically, by email, file transfer or remote access to servers
• verbally, by phone, video conference or in-person briefings overseas
• visually, by someone reading a document or viewing a demonstration
• through cloud storage, by making controlled technology available to people outside the UK, even if the server is in the UK

The UK does not have 'deemed exports'. Transferring controlled technology to a non-UK national solely within the UK is not considered an export. However, sharing that same technology with someone overseas (including by granting remote access) does require a licence.

Types of export licence

There are no fees for export licence applications. Three main licence types are available:

• An Open General Export Licence (OGEL) is pre-published and covers specified items to specified destinations. You register on SPIRE and comply with its conditions, with no individual application, and ECJU audits your compliance.
• A Standard Individual Export Licence (SIEL) covers a specific shipment of specified items to a named consignee and end-user, and is valid for 2 years. ECJU aims to process 70% within 20 working days and 99% within 60.
• An Open Individual Export Licence (OIEL) covers repeat exports of specified items, usually needs an established track record (replacing at least 20 SIELs a year), and is valid for up to 5 years.

Always check whether an OGEL covers your export first — it is the quickest and simplest route.

End-use controls (catch-all)

Even if your goods are not on the control lists, you need a licence if:

• The ECJU has informed you (via an 'informing letter') that a licence is required for a particular export
• You know or suspect the goods may be intended for WMD purposes (chemical, biological, nuclear weapons, or missiles capable of delivering them)
• The goods could be used for military purposes in connection with a destination subject to a UN or OSCE arms embargo, or listed in Schedule 4 of the Export Control Order 2008

Red flags that should trigger concern include a customer reluctant to provide end-use information, product capability not matching the stated end-use, refusal to provide an end-user certificate, orders inconsistent with the customer's normal business, or unusual shipping routes or payment terms.

Sanctions interaction

Sanctions override export licences. Even if you hold a valid export licence, exports are prohibited if they breach applicable sanctions regulations. Always check the UK Sanctions List before any export.

From 28 January 2026, the UK Sanctions List (maintained by FCDO) is the single source for all UK sanctions designations, replacing the previous OFSI Consolidated List.

Russia sanctions are the most comprehensive, prohibiting export of all dual-use goods, all military goods, and a wide range of industrial goods. HMRC compound settlements for Russia sanctions breaches have exceeded £1.1 million in a single case.

Penalties and records

Exporting controlled items without a licence is a criminal offence. HMRC may offer compound settlements for inadvertent breaches, but these can still run into millions. You are responsible for working out whether your goods need a licence, and not knowing is no defence.