On 26 October, an article from Travers Smith was concerned with the rules from 1 January and the new guidance issued by UK authorities on 16 October. It says that, prior to 1 January, the export of these items from the UK to the EU remains broadly unfettered, save for a small number of the most high-risk items subject to individual controls at a state level. This situation is replaced from 1 January by a new regime which includes new a new Open General Export Licence (OGEL) which relates to the export of systems, equipment and components, test inspection and production equipment, materials, software and technology, and covers all areas of production. While advising all exporters to review their own situation, the article says that, whilst it is not anticipated this change of rules will have a significant impact on seasoned exporters, it does mean that many new businesses will require an OGEL.
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