If we make a component for which has a final destination on an oil rig, however we ship the component from the UK to the US who manufacture the final product – do i need a licence?
(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)
Since this is a detailed and particular question, then you would be better contacting the ECO directly
Thank you for your question.
Unfortunately it isn’t clear from your question whether or not the component you are exporting is described by the control lists. (https://www.gov.uk/government/publications/uk-strategic-export-control-lists-the-consolidated-list-of-strategic-military-and-dual-use-items-that-require-export-authorisation)
If your goods are on the list then licence coverage is required to Export your component from the UK to the US as the manufacturer who uses your component is the End-User. If it is known at the time of export who the Ultimate End User is (i.e. the entity that uses the manufactured goods, e.g. an Oil-Rig), then this information can be submitted as part of a Licence application to support it.
However, if the goods are EU Dual Use goods, and not Annex IV (shown in the margins of the Consolidated Control List above by a ‘IV’), then you may be able to use the Community Authorisation EU-001. This is a Licence, but with record keeping and notification requirements that are much less burdensome than applying for a Standard Individual Licence (SIEL). Full details are at: https://www.gov.uk/guidance/european-union-general-export-authorisations