The UK’s national customs office issued £200,000 in fines to UK businesses for exports of unlicensed military and dual-use goods in 2021.

Between March and November last year, Her Majesty’s Revenue & Customs (HMRC) issued compound penalties between £1,000 and £54,000 to 10 UK exporters.

Seven of these fines were for the export of military rated goods without the appropriate licence, and three were for the export of dual-use goods without the appropriate licence.

All 10 cases were found to be in contravention of the UK’s 2008 Export Control Order, following an investigation by the Export Control Joint Unit (ECJU).

What is a controlled item?

The 2008 Export Control Order determines what types of goods are “controlled” due to military or dual-use potential.

The broad categories include:

  • items specifically designed or modified for military use and their components  
  • dual-use items that can be used for civil or military purposes
  • associated technology and software
  • goods that might be used for torture
  • radioactive sources

UK exporters can find a consolidated list of such items here, published by the ECJU and the Department for International Trade (DIT).

The UK’s website also offers an online checker for businesses to establish whether the goods they intend to export are controlled.

In such cases, the goods may be subject to a general export licence (OGEL), or they may be listed under a control list entry (or “rating”), which means the exporter needs a special licence from the ECJU.

The UK updates its strategic export control lists about twice a year, and it is the responsibility of the exporter to ensure that they are aware of all recent updates and licensing rules.