The EU has launched a consultation, closing on 30 November, saying that awareness about dual-use export controls in the wider research community cannot be taken for granted. In the EU, only few research organisations have a fully-fledged compliance structure established. Most research organisations are only starting to invest in export compliance measures, including the determination of potentially export-controlled research, and seek support from EU and national competent authorities.  The public survey is to evaluate the usefulness of the draft 64-page guidance provided by the EU, providing the opportunity for relevant stakeholders to give their feedback and inputs. The guidance has 4 sections –

  1. Section 1 summarises how research organisations can be affected by EU and national dual-use export control regulations and how important top-level management commitment to compliance is to implement proportionate and effective internal compliance measures;
  2. Section 2 provides for awareness information for researchers, including the basics of dual-use export controls and the potential impact on research related activities;
  3. Section 3 provides for specific guidance to compliance staff on how to set up and review an Internal Compliance Programme 9ICP); and
  4. Section 4 gives an overview of the regulatory framework for dual-use export controls.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

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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