If our products are not in the export control list and the Buyer is not in the list, do we still have to apply for an export license?

Question

If our products are not in the control list and the Buyer is not in the list, do we still have to apply for an export license?

(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

If you have checked both the military list and the dual use list and have confirmed that your goods are not listed (beware that you need to word the term carefully if you are doing an automated search – searching for “pistol” will only bring up signal pistols in the military list as they are described as “handguns” instead), and you are not shipping to a sanctioned or embargoed destination then there is no need to apply for a licence.

Just be careful where control entries contain “and parts and components therefore” which may widen the scope of the control.

Answer

Dear David,

Thank you for the respond.

We are trying to expand our activities to Iran.

Our equipment and parts are not in both military and the dual use list and also not in the strategic control lists.

As far as I understand from your email, as Iran is a sanctioned or embargoed destination, anyhow, we have to apply for an export license. Is that correct?

Thank you in advance for your comments.

Benan Betik

Answer

Benan, unfortunately my experience of Iran and exports to Iran is zero having worked within the defence industry so I don’t know for certain. I know that Iran is “opening up” as a destination for UK companies, but there will still be entities who are embargoed and therefore it would be best to speak to the ECO.

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