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Impact of Brexit on Dual Use Items Trade from EU to UK

(S,P) Dual-Use Items may require a licence to export to the UK from the EU. Here is what you need to know.

Three things you need to know and do before you send goods to the UK from the EU

  1. Shipments of listed dual-use items from the EU to the United Kingdom are subject to an authorization requirement under Regulation (EC) No 821/2021

  2. Don't rely on licences from the United Kingdom for shipments from the EU to a third country;

  3. Don't rely on licences issued by the relevant licensing authority in a Member State for export of items located in the United Kingdom to another third country after the end of the transition period; and

UK Export Licences are no longer valid to export out of the EU

  • Export licences issued by the United Kingdom under Regulation (EC) No 428/2009 are no longer valid for exports of dual-use items from the EU to third countries.

  • Rather, such exports of dual-use items from the EU to third countries will require a licence issued by the competent authority in the relevant EU Member State.

Intra-EU transfers are Exports

  • Very sensitive dual-use items, listed in Annex IV to that Regulation, are subject to intra-EU transfer controls.

  • Former transfers of Annex IV items from the EU to the United Kingdom now constitute an export subject to authorisation under the terms and conditions of Regulation (EC) No 821/2021

Northern Ireland

  • The IE/NI Protocol provides that Regulation (EC) No 821/2021 applies to and in Northern Ireland.

  • Shipments of dual-use items from the EU to Northern Ireland, and vice-versa, are intra-EU transfers for the purpose of Regulation (EC) No 821/2021;

  • Shipments of dual-use items from Northern Ireland to a third country or to Great Britain are exports for the purpose of Regulation (EC) No 821/2021.

  • In that case, the UK designated authority is to act as the competent authority for the purpose of the application of Regulation (EC) No 821/2021.

  • The IE/NI Protocol excludes the possibility for the United Kingdom in respect of Northern Ireland to participate in the decision-making and decision-shaping of the Union; invoke mutual recognition of assessments and authorisations by the United Kingdom in respect of Northern Ireland.

More specifically, this means the following:

any authorisation issued by the United Kingdom in respect of Northern Ireland under Regulation (EC) No 821/2021 cannot be invoked for shipments of dual-use items from a Member State to a third country.


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