On 1st February, Loyens & Loeff published an article about a proposal by the EU Commission to add the UK to the list of destinations covered by the Union General Export Authorisation (EU001) for the export of dual-use goods if there is a no deal Brexit on 29th March.  Presently, the “export” of dual-use goods from another EU state to the UK is, in general, not subject to licensing.  However, if the UK should leave the EU on 29th March without a deal, the export of dual-use goods to the UK will require an export licence.  Therefore, the Commission now seeks to add the UK to the destinations covered by licence EU001 (i.e., Australia, Canada, Japan, New Zealand, Norway, Switzerland (including Lichtenstein), and the USA).  It explains that such general licences require timely registration, usually at least 2 weeks before actual export takes place. They are not completely without administrative burden, however. Box 44 of the respective customs declarations needs to record use of the licence and national regulators will normally require periodical reports on the exports that have taken place under a general licence.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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