Is EC approval required for dual use goods not originating in the UK?


what if we are exporters of dual use goods that do not originate in the UK and are shipped from another country ? Do we need EC approval ?

(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


The EU Dual Use List applies in all member states, therefore the licensing would apply in whichever country your goods were shipped from.


Many thanks for your clarification David. If the goods are being shipped out from say Japan or UAE to another non EU country, but the Invoice is done in the UK, do we need Export Control approvals?


Harbinder, in that case you would be considered to be brokering the deal and would need to check whether that activity would be controlled. You would also need to consider the export control regime in the country of export.

Export Action Plan