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Export controls

Please check the list of Key Countries which are under current trade sanctions, including arms embargoes and other restrictions.

In the event of a No-Deal Brexit

This update concerns University staff and students who are currently involved in export-controlled activities in relation to EU member states. Should the UK leave the EU without a deal, the export of controlled goods/technology to EU member state(s) will need an export licence. The UK Government has created an Open General Export Licence (OGEL) to allow for the continuation of such exports after the UK leaves the EU. This specific licence will only come into force after the UK leaves the EU. The University has already registered the whole organisation for this specific OGEL. Our OGEL number is OGE2019/000216. There are conditions to using this licence:

  1. When exporting physical goods/items, the following statements must be included: "This [insert item name] is [a] UK Export controlled [insert item name], categorised by code [insert UK export control code] of the EU Dual-Use list. Exported to [insert destination country] under licence number OGE2019/000216. A licence might be required by your organisation to export this [insert item name] outside the EU: it is your organisation’s responsibility to check whether such a licence is required. Advice on licencing should be sought from the relevant national authority where the [insert item name] is exiting the EU."
  2. The statements above must be included in every shipping document, purchase order and invoice, relating to the export of controlled goods/items to EU member state(s). The statements do not have to be included with every transfer (electronic or otherwise) of export controlled technology/information.
  3. Records of each export or transfer (electronic or otherwise) only relating to export controlled goods/technology, under this OGEL, must be kept for at least 4 years. Use this record keeping template to capture all the required information.
  4. For exports of goods/technology covered by Category 0 - Nuclear materials, facilities and equipment, please refer to 4 (7) of this specific OGEL or contact the Export Controls Compliance Project Team.

Why do we have export control?

All member countries of the UN are required to have a system of controls on exports of certain goods and technologies that- in addition to legitimate civilian applications – may also be misused for severe human rights violations, terrorist acts or the development of weapons of mass destruction (WMD). In some instances, individual academics may need an export licence from the Export Control Organisation (ECO) in order to carry out an activity related to their research – failure to obtain one being a criminal offence.

Export controls are not unique to the UK, all countries should have some form of an export control policy, legislation and enforcement mechanisms. Some countries such as the US may impose limitation clauses on the way in which the recipients may use or share the import. This could include restricting access of the import to citizens of restricted countries. UK export controls do not impose such limitation clauses on recipients.

What does export mean?

Export controls apply to goods, technology, software and/or knowledge “exported” outside of the UK in the following ways:

  • Physical removal/transfer (shipped/freighted overseas – e.g. carriage of a laptop on a trip)
  • Electronic transfer (facsimile, e-mail, telephone, text message, video-conferencing).

Under exceptional circumstances export controls apply to transfers within the UK when the known ultimate end use is WMD related outside the UK.

What is controlled?

Strategic military and dual-use items that require export authorisation are published in the consolidated UK Strategic Export Control List. (note: the link works with Chrome, not IE)

There are four primary elements of the UK Strategic Export Controls:

  1. Export of military, paramilitary and radioactive items to any destination outside the UK.
  2. Exports of controlled dual-use technologies to destinations outside the EU – generally these are civil items and technologies that could be used for WMD purposes or potentially have military application.
  3. Export of more sensitive dual-use items of technology to any destination including within the EU.
  4. “Catch-all” control. This is based on end-user concerns and is intended to control goods and technologies which are not listed but which have a possible utility in an area of concern:
    1. For WMD, namely for chemical, biological or nuclear weapons or explosive devices
    2. For a military end-use in an embargoed destinations.

The Export Control Organisation provides online checker tools which help to establish if items/knowledge are controlled and require an export control licence and to identify if an appropriate Open General Export Licence (OGEL) exists (note: the link works with Chrome, not Internet Explorer).   If you are going to register for an OGEL, you must ensure you can meet all the terms and conditions, before registering via SPIRE. If either no OGELs exist or you cannot meet all conditions, you will need to apply for a Standard Individual Export Licence (SIEL) via SPIRE. Applications via SPIRE need to be done through an institutional login, for more information please contact the University’s Export Controls Compliance team at ecc@manchester.ac.uk.

Useful websites:https://www.gov.uk/government/organisations/export-control-organisation