Are parts and accessories of a controlled item also considered controlled items?

Question

Are parts and accessories of a controlled item also considered controlled items?

(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

That would depend. It is possible that you would use commercial off the shelf parts in order to make an item that is controlled, in which case those parts would not be controlled.

The UKML does have some entries that refer to “parts and components therefore” in which case the control does spread further than the top level article.

Answer

Dear Ross

Most of the controls for lasers are in Cat 6 of the EU Dual Use List. There are a few controls for very specialist laser on Cat 0 of the list. Use the Goods Checker https://www.ecochecker.bis.gov.uk/spirefox5live/fox/spire/ or the Search Tool on SPIRE to determine the technical specification of the controls.

All controls in the dual use list cover Systems, Equipment and Components of the controlled items ie parts

Answer

That would depend. It is possible that you would use commercial off the shelf parts in order to make an item that is controlled, in which case those parts would not be controlled.

The UKML does have some entries that refer to “parts and components therefore” in which case the control does spread further than the top level article.

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