Advice on filing a SIEL for goods sent to a distributor

Question

Can you explain how to file a SIEL for a distributor located in Israel buying products from a Uk manufacturer when such distributor is then reselling the products to several customers incorporating products for a final end user (the israeli army) ?

Should i file one Siel for every product i’m selling to such distributor ?

(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/)

Answer

Hi
Since this is a detailed and particular question, then you would be better contacting the ECO directly
Tel 02072154594
eco.help@bis.gsi.gov.uk
https://www.gov.uk/government/organisations/export-control-organisation
thanks
Gilio

Answer

Unfortunately it isn’t clear from your question the full scenario, but hopefully one of the following scenario’s suit your question.

1) If a UK exporter is exporting goods to a distributer who knows who the goods are going to be then sent to for incorporation, e.g. a manufacturer, then the manufacturer is the End User, according to our on-line guidance: https://www.gov.uk/guidance/submitting-export-licence-applications-correctly

You will then need to get an End User undertaking from the manufacturer using/incorporating your controlled goods. The distributer will then either be the Consignee (if as described in the link), or a 3rd party. You will also need to apply for a licence for each End User separately, even though the goods are going via the same distributer. The Israeli Army would be the Ultimate End User in your example. Our advisors will then consider your application accordingly.

2) The licensable goods are being exported and held by a stockist, without knowing which End-Users each of the goods are going to be then exported to. In this scenario the Stockist will need to complete a Stockist Undertaking (in the link above) and the Licence Application will be considered by our advisors accordingly.

It is important that any application contains all of the known information about an export and how/where the goods will be used. Missing information, or area’s of risk or doubt, may delay an application. If there is considered too many unknowns or too much risk, this may result in an application being refused.

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