We are a Canadian-based manufacturer of oil completion tools with an office in Aberdeen that is responsible for EMEA, South Asia and AsiaPac. We export to Russia – within the rules promulgated by the US and EU – from the UK office. None of our products are dual-use, but are contained in Annex II so a license is required. We were successful in obtaining licenses last year and was audited by ECO late last year. The vast majority of our exports to Russia are parts used in our finished product (which do not require a license). Our subsequent export license applications are taking a long time to be reviewed even though they are low value, not dual-use, and already reviewed by ECO. As was the end-user and our company.
How can we make the process faster?
(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/)
The processing time of applications to the ECO depends on a variety of factors, including: Destination, goods, supporting information and risk.
The more information you can provide to support your case, the more likely your case will be processed faster. As a minimum provide:
• The goods and/or technology you wish to export.
• The consignee and, if different, the end-user of the goods and of any third party involved in the transaction.
• The intended end-use of the goods, including (where known) the project name and the location where the goods will be used.
The ECO aims to process 70% of licences within 20 Working Days (not including the time waiting for answers to Requests for Information.) Our official statistics for the last quarter of 2015 for Russia shows that the median time for processing licences was 20 Working Days. So if your applications are taking about this length of time, then there may be little more that can be done to expedite them.