Is there a specific customs regime to allow transit of dual-use item from a 3rd country to another 3rd country with transit within EU, without EU export licence?

Question

Is there a specific customs regime to allow transit of dual-use item from a 3rd country to another 3rd country with transit within EU, without EU export licence?

(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

In order to provide you with further guidance, we need more information about the exact nature of the export.

Are the goods arriving in the UK from a 3rd Country and going out on a flight direct to another 3rd country?  We could only comment if the specifics are relating to the UK.   If you’re based in France we are unable to comment on their procedures for Transit and or licensing.

If your query relates to licencing in the UK please contact BIS on 0207 215 5000.

If you have questions about UK Export law please phone Export Team on 03000 582418.

Lines are open from 9am to 3.30pm Monday to Friday.

HM Revenue & Customs

Customs International Trade & Excise

www.hmrc.gov.uk/contactus

Answer

Hello,
Thank you for your answer.
My question was not UK specific but I’m interested in an answer for UK. I have 2 scenarii.
a) US controlled goods (with US bulk export license) arriving in a custom bonded area in the UK, in transit, to be exported to Gabon. Does this second export require a UK export license or is the declaration of the US bulk sufficient?
b) US controlled goods (with US bulk export license) arriving in a custom bonded area in the UK, in transit, with final destination in Rotterdam in the EU. Does this second shipment through EU require a UK (export/transfer?) license or is the declaration of the US bulk sufficient?
Thank you for your feedback.
Best regards,
VH.

Answer

Export Control Order 2008 Article 8. The arrangements in the UK are that most military and dual-use goods can pass through the UK en route to another pre-determined overseas destination without the need for a UK licence provided the exporter has complied with certain conditions. However, sometimes, you will need a transhipment licence where either the goods or the destination country – or both – represent a sufficient degree of risk. Open General Transhipment Licences are similar to Open General Export Licences, which are available in the public domain, subject to specific terms and conditions. There are 4 different types of OGTL and you will need to read when they can not be used. see https://www.gov.uk/guidance/transhipment-licences#restrictions-exceptions-and-enforcementThere may be similar arrangements in other EU countries, but you will need to check with the relevant Customs or Export Control Authority.

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