A January 2019 briefing from Irish law firm Arthur Cox points out that “export” only refers to goods sent to a destination outside of the EU customs territory. For the transfer of dual-use goods within the EU customs territory, no authorisation is required (with some limited exceptions). Of course, if the UK leaves the customs territory then this exemption will no longer apply to dual-use exports from Ireland to the UK. However, the European Commission has published a draft Regulation which would include the UK on the list of countries which are subject to UGEA Category 001 (i.e. for a form of general licence). The Irish Government has said that exporters currently exporting or planning to export dual-use goods to the UK, notify its Export Licensing Unit of now in order to avoid any potential processing delays – and that a national licence may be put in place should there be a delay to the EU general licence.