If you start to manufacture military controlled goods in another country (not UK) and control the export of the technology to that country, are the finished goods subject to UK export control ?

Question

If you start to manufacture goods that are military controlled items usually supplied out of the UK under an OGEL or SIEL, in another country (not UK) and control the export of the technology to that country, are the finished goods subject to UK export control ? or only the regulations in force in the country of manufacture

(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

The UK export controls are not extra territorial like the US controls – if you were to do the same thing with US origin technology your would still be manufacturing a US controlled article – so the item would only be controlled by the regulations in the country of manufacture.

Depending on how the design of the article was originally funded, you may need to contact the MoD to get a grading in order to confirm that it would be possible to manufacture the goods outside the UK as due to national security requirements there are some technologies that the UK would rather not get into the hands of other nations. If you funded it yourself you would need to speak to DDefSy for a PV Grading and maybe get F680 approval prior to starting the overseas manufacture.

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