Do products being returned for repair or spare parts for an item previously exported under a SIEL need a license as well?

Question

If you originally exported an item with a Standard individual license, do products being returned for repair or spare parts for an item previously exported need a license as well.

(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 https://opentoexport.com/info/webinars/)

Answer

If they are military goods, depending upon the destination the goods returned from in order for you to carry out the repair, there is a chance that you would be able to use the OGEL Export after Repair/Replacement under Warranty: Military Goods, but ensure that you read the terms and conditions carefully as there is evidence that you need to retain of the original export and subsequent import for the purposes of the ECO audit.

Answer

Yes you will need a licence for export for repairing goods – but you should look first at the Open General Licences (Export for Repair) for military and dual use goods
https://www.gov.uk/government/publications/open-general-export-licence-export-for-repair-replacement-under-warranty-military-goods–7
https://www.gov.uk/government/publications/open-general-export-licence-export-for-repair-replacement-under-warranty-dual-use-items
They cover a wide range of control list entries and can be used for most destinations. You will not require a licence for EU member states and may be able to use the EUGEA001 to send the goods for repair to Australia Canada Jpan New Zealand Norway Switzerland (including Liechtenstein) and USA

Answer

I should also add that your Compliance Inspector will be happy to answer any questions in relation to Open Licensing – please make contact direct

Export Action Plan