End User Undertaking (EUU)

Question posted by Alan Long

I am seeking clarification/help on whether my company Flann Microwave Ltd need to request an end user undertaking statement from International customers. The current company policy is to always request an EUU. For countries such as Israel, Singapore, India et cetera I believe that we are losing business as customers are stating they can purchase equivalent items from other suppliers without the need for an EUU. Flann Microwave Ltd manufactures passive waveguide products that can have military applications however they are not specifically designed and used for this purpose.

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Sandra Strong, on behalf of Strong and Herd LLP in M22.

Hi Alan
I understand the difficulties you are facing, we work a lot with companies who have military or dual-use products and technology. You say your passive waveguide products have military application potentials but you haven't said whether they fall within the high tech levels on the DUEC (ie 3A001.b) or the risk is only if they are put to a military end-use that comes under UK/EU/UN/USA controls.

Also I don't know if you are sending out a brief End-user statement or asking them to complete the full 3 page ECO EUU (rather daunting even when required).

It's all about assessing risk - risk of WHAT you are sending, WHERE it is going, WHO it is going to and WHY they want it. Due diligence supported when necessary by EUS/EUU i the way forward.

If I can help further please get in touch sandras@strongandherd.co.uk

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