Further acknowledgement of delays at ECJU
The Export Control Joint Unit (ECJU) has published further guidance aimed at encouraging applicants to reduce the Unit’s workload. The guidance reminds licence applicants about the ‘End User Advisory Service’ which enables exporters to seek advice on whether exports will require licences because of Weapons of Mass Destruction (WMD) or military end use concerns.
The unit is currently processing around 14,500 enquiries per year, which has increased substantially because of Russian sanctions, as well as the enhancement of the Government’s Military End Use Controls and their inclusion of China. Enquiries about Chinese end users alone have increased by 14.5% from May 2022, when the Military End Use Control changes took effect, to April 2023.
Acknowledging the delays, particularly for Russia and China the guidance asks applicants to avoid submitting unnecessary queries.
The End User Advice Service should only be used by exporters who have already established that their goods do not feature on any control lists and will therefore not normally require export licences. Those who have applied to the EUAS before, and been told that there are no concerns, need not seek further advice for the same equipment going to the same end user for six months. If however, you have received the response that there are concerns, that will apply for a year.
Those exporting exclusively to the following countries, do not need to apply to the End User Advice Service:
Australia, Austria, Belgium, Bulgaria, Canada, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom, United States.
Further information is available here.
Consolidated list of strategic military and dual-use items that require export authorisation
End-use controls applying to WMD-related items, including technical help
End-use controls applying to military related items
New overseas undertaking forms
The ECJU has also updated the forms to be completed by overseas undertakings when an export licence is required. The overseas end-user or consignee receiving the items must complete the form and supply a covering letter on the original official headed paper of the overseas company.
The UK exporter is responsible for putting the completed documentation for the SIEL or SITCL in SPIRE, the online export licensing system as part of the licence application process.
The new form can be found here.