If a U.K. company modifies one of their automotive parts for a military end-use, will that always be considered subject to the Military control list?

Question

If a civilian automotive company in the U.K. modifies one of their automotive parts for a military end-use, will that always be considered subject to the Military control list? For example, what if the modification is the same type of modification they would make for their civilian customers. For example, modifications made to fit and form only,, and not 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 http://opentoexport.com/info/webinars/)

Answer

Thank you for your question.

This is one of the more difficult general questions to answer as it depends on what modifications are being applied, and why (what we call a ‘case by case’ issue).

If the modification is for a Military ground vehicle, then please refer to ML6 of the Export Control Order of 2008 (found within the Consolidated Control List, link to follow). It covers components ‘specially designed or modified for military use’.

I would advise that if a manufacturer is asked to modify a part for a military end-use, then this is the point at which they should consider applying for an Export Licence. It should fully explain the original use of the part, the modification(s) requested. why they are needed and what the part is ultimately going to be used in. The ECO can then assess the part in context.

The Consolidated Control List is found at:
https://www.gov.uk/government/publications/uk-strategic-export-control-lists-the-consolidated-list-of-strategic-military-and-dual-use-items-that-require-export-authorisation

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