Export Controls: Is a change of colour alone enough to make an item be classed as for military use?


If an item which was originally designed for industrial/commercial use is ordered for a military application, with a specification change relating to a change of colour only (change of colour to green for example), would the item subsequently be considered a ‘military item’ requiring an Export Licence (to confirm – colour change to green only, no other change of fit, form or function) ?

(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/)


If the paint is a specialised paint used only for military purposes – CARC paint for example to protect against chemical agents – then your product is likely to become controlled, but if you use an off the shelf green paint with no other change to fit, form or function then it may well remain uncontrolled.


If there is no design change or modification to the item for the military application then it would still be considered as a Dual Use item. Provided that the paint used to make the item green does not have signature suppression capability, changing the colour of a dual use item would not make it military. Where a colour change can make a difference is in the screen display used for radar systems. If these are normally green but the military request one in amber, this would change the operation of the equipment (i.e. may improve night time use) and so would be seen as a modification for military use.

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