If shipping something under an export licence, do technical documents such as operating manuals become export controlled?
Question
If shipping something under an export licence, do all of it’s technical documents such as operating manuals become export controlled. Also if an End User requests these document’s after an Export Licence has expired, will a new Export Licence be required?
(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/)
Answer
If the technical manuals contain information required for the use of the controlled equipment then the chances are it is controlled technical data.
If your hardware is shipped on a SIEL then there’s a possibility – depending on the destination – you could ship the technical data under the OGEL technology for military goods rather than getting another SIEL.
Answer
) Information technology controls cover “information necessary for the development, production or use of controlled goods”. If the operating manuals contain any of this type of information, a licence is required. You can add it as a line item in your licence application. See the guide https://www.gov.uk/guidance/export-of-technology. Exceptions include:
• technology needed for installing, operating, maintaining and repairing controlled items that have already been authorised for export
• information that is the minimum needed to install, operate, maintain and repair non-military items, even if this information could have a military use
• information already in the public domain – for example a user manual that is feely and legally available on a public website