Exporting dual use product

Question

I work within the IT industry and we export dual use product classified under ECCN 5A002.a.1.a. To reduce the lead time of applying for a SIEL for each shipment is there a service provider within the UK that is able to use their OIEL to export dual use goods for another organisation?

Answer

Hi there Paul,

In all honesty I do not know the answer to your question but my feeling on this is that the answer would be no as licenses are issued very specifically to exporters and with good reason. Certainly wouldn’t look to try and cut any corners when it comes to licensing requirements because of the potentially severe implications of getting it wrong.

I imagine you must be acquainted with the Export Control Organisation and so would recommend speaking with them to see if there is a more amicable solution can be offered to your problem. Sorry I can’t be of more help on this occasion.

Kind regards,

Simon.

Answer

You can’t use someone elses licence. If its your goods, you have to obtain the licence I’m afraid. OIELs are also specific about the site the goods are exported from.
As the previous responder identified, if you get it wrong its you who carry the penalties.
If you export regularly to the same consignees why not consider an application for an OIEL yourself?
I’d be happy to chat through the options with you.

Answer

Hello Paul
Depending upon which country you are exporting to, you may be able to use an Open General Export Licence (OGEL). If there is an appropriate OGEL for your products you need to register to use it and once registered you don’t have to apply for a licence for each export which saves considerable time. OGELS are only valid for certain countries and have a set of terms and conditions that must be complied with. You also have to keep a record of all exports made under OGELs and you will be subject to audits by ECO. If you want to explore this option further I’d be happy to help so please please feel free to contact me (e-mail chris@accesstoexport.com or tel. 01223 890767)
Kind regards
Chris

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