Some items in our product catalogue are subject to export licensing regulations. We are totally compliant in exporting these products using suitable export licence cover whether SIELs (Standard Individual Export Licences) or OGELs (Open General Export Licences). The question arose recently concerning an instance where we received an order from a UK based company for an item that was subject to export licence requirements, we supplied the item without query but it later came to light that the item had been exported from the UK. How do we stand in relation to other UK parties exporting our product?

The responsibility for complying with Export Control legislation rests primarily with the party who is making the export (the exporter of record) and declaring it to Customs. Nevertheless it is an easy procedure to include a short cautionary note on your response to enquiries pointing out that some of your products are subject to export licensing requirements and any subsequent export must be executed in line with these rules. This procedure indicates to the authorities that you are keen to encourage compliance but clearly although your power to exert control is limited you should understand the underlying aim of export controls in reducing proliferation and controlling strategic technologies which may assist in terrorist activity and attempt to control the end use of your products.


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