A laser measuring head, specialist chemicals or an encryption module may each need an export licence before leaving Britain. Exporting dual-use goods from the UK is one of the few areas where a routine B2B shipment to Poland or Germany can turn into a criminal matter if the paperwork is missing. This guide explains how to check whether your goods are controlled, which licence fits and what has to appear on the customs declaration.
What counts as dual-use goods in the UK
GOV.UK defines dual-use items, including software and technology, as items that can be used for both civil and military purposes. The rules cover physical goods, but also software and technical data – the guidance lists email, file transfer, telephone and video conferencing among the ways technology can be transferred.
For Great Britain the controlled items are listed in assimilated Council Regulation (EC) 428/2009, while Northern Ireland applies Regulation (EU) 2021/821. The reference list to check is the government’s consolidated list of strategic military and dual-use items. Dual-use entries are organised in categories 0 to 9 (from nuclear materials to aerospace and propulsion), each split into sub-groups A to E: systems, equipment and components; test, inspection and production equipment; materials; software; technology.
The legal framework is the Export Control Act 2002 and the Export Control Order 2008, and GOV.UK is explicit that breaching export controls is a criminal offence.
Step one: classify your goods against the control list
Export control classification is separate from finding a commodity code: the tariff code drives duty, while the control list decides whether the Export Control Joint Unit (ECJU) must authorise the export. A product can sit on the dual-use list because of a technical parameter such as accuracy, frequency or purity.
Practical sources for classification:
- the technical specification from the manufacturer (many producers state the control list entry on the datasheet),
- the consolidated list published on GOV.UK,
- the goods checker and OGEL checker tools mentioned in the UK strategic export controls guidance,
- the control list classification service on SPIRE, where you can ask ECJU to classify your item.
Catch-all controls: when an unlisted item still needs a licence
An item that is not on the list is not automatically free to export. GOV.UK explains that the government has powers to require a licence for items that are not on the consolidated list – the so-called catch-all or end-use controls. They apply in particular where goods may be intended for weapons of mass destruction programmes or certain military end uses. If you have concerns about the intended end use, it is safer to seek advice from ECJU before shipping.
Exporting dual-use goods from GB to the EU: the OGEL route
Since Brexit, a shipment of listed dual-use items from Great Britain to an EU member state is an export that needs authorisation. For most listed items the practical answer is the open general export licence (export of dual-use items to EU member states), last updated on GOV.UK on 16 December 2025. According to the licence text:
- it covers exports to all 27 EU member states, plus the Channel Islands and Iceland,
- not every listed item is covered – for Great Britain, items in Annex IIg of the Regulation are excluded (see Schedule 1 of the licence),
- you must register on SPIRE before you first use the licence, giving the address where your export records can be inspected,
- export documents must carry either a note that the items go under this OGEL or your SPIRE reference in the form GBOGE 20XX/XXXXX (this does not apply to technology sent by phone, fax or other electronic media),
- that GBOGE reference must also be entered on the UK customs declarations system,
- records of each export must be kept for at least three years from the end of the calendar year of the export,
- if you do not use the licence within any 24-month period, your registration lapses and you have to register again.
The OGEL cannot be used if you have been informed or know that the items are intended for a WMD-related end use, or if you suspect such a use and have not made all reasonable enquiries. It also cannot be used if you know the final destination is outside the permitted countries and no processing will take place there, unless the direct export to that final destination would itself be covered by another licence. For exports from Northern Ireland, GOV.UK states that no licence is needed to send controlled dual-use items to the EU – check the current guidance before relying on this for a specific item.
When you need an individual licence (SIEL or OIEL)
If the goods or destination fall outside an OGEL, you apply for an individual licence. The GOV.UK guidance on standard individual export licences (updated April 2026) says a SIEL suits exporters who cannot meet OGEL terms and can name the quantity and consignee. You need the technical specification and an end-user undertaking signed by the end-user or stockist. Permanent SIELs are generally valid for two years or until the quantity specified has been exported, and ECJU aims to decide 70% of applications within 20 working days. Most SIEL applications now go through a newer online service, while some licence types still use SPIRE. For repeat business with the same customer, an open individual export licence (OIEL) may be available to exporters with a track record of licence applications or a demonstrated business need.
Dual-use and the customs declaration
An export licence and an export declaration are two separate obligations. The licence comes from ECJU; the declaration is made in CDS (the UK customs declarations system) by you or your customs agent, and the licence reference entered there has to match your registration. If you ship regularly to Poland, it is worth agreeing the licence data with whoever handles your export customs clearance from the UK before the goods are collected. A short Polish-language explainer on dual-use export permits from the UK is useful for your EU customer, and destination checks should include current UK trade sanctions and restrictions. For the wider picture, see our guide to sanctions and embargoes in UK trade.
Checklist before you export dual-use goods from the UK
- Get the full technical specification and check it against the consolidated control list.
- Record the control list entry (or a reasoned “not listed” note) in your files.
- Screen the customer, end-user and end use for catch-all red flags and sanctions.
- Check whether an OGEL covers the item and destination; register on SPIRE before first use.
- If no OGEL fits, apply for a SIEL with an end-user undertaking well ahead of the shipment date.
- Put the licence wording or GBOGE reference on the invoice and export documents.
- Give your customs agent the licence reference for the CDS declaration.
- Keep export records for at least three years from the end of the calendar year.
Mini-FAQ
Do I need a licence to export dual-use goods from the UK to Poland or Germany?
If your goods are on the UK control list, yes, you need an export authorisation even for EU destinations. For exports from Great Britain, most listed dual-use items can go to EU member states under the open general export licence for dual-use items to EU member states, but you must register for it on SPIRE before you first use it and meet its conditions. GOV.UK states that no licence is needed to export controlled dual-use items from Northern Ireland to the EU.
What is the difference between an OGEL and a SIEL?
An open general export licence (OGEL) is pre-published by the government: any exporter can use it after registering, provided the goods, destination and conditions match. A standard individual export licence (SIEL) is granted to a specific exporter for set items, quantities and a named consignee or end-user, and needs supporting documents such as an end-user undertaking.
My product is not on the control list. Can I export it freely?
Not always. GOV.UK explains that the government can require a licence for items not on the consolidated control list under so-called catch-all or end-use controls, for example where you are told, know or suspect that goods may be intended for weapons of mass destruction or certain military uses.
What must appear on the customs declaration when I use the EU dual-use OGEL?
The current licence text requires your registration reference in the form GBOGE 20XX/XXXXX to be entered on the UK customs declarations system. Commercial and official export documents must also carry either a note that the items are exported under this OGEL or that SPIRE reference.
Sources (gov.uk): Export controls: dual-use items, software and technology; Open general export licence (export of dual-use items to EU member states); Standard individual export licences (SIELs); UK strategic export controls. Licence terms change – always check the current version on GOV.UK before exporting.