NTE 2025/13 advises that The Export Control (Amendment) Regulations 2025 (the Regulations), amend the Export Control Order 2008 and the assimilated Council Regulation (EC) No 428/2009 of May 2009, setting up a Community Regime for the control of exports, transfers, brokering and transit of dual-use items. 

To align with the regulations administered by multilateral export control regimes as part of the UK's International commitment to Export Controls, the following changes have been made:   

Schedule 2 to the 2008 Order (Military Goods, Software and Technology): 

Amendments to reflect routine technical updates to controls on the exports of conventional weapons agreed through the Wassenaar Arrangement. Included are the deletion or replacement of some definitions and editorial amendments relating to the following categories: ML1, ML2, ML7, ML10, ML13, ML19 and ML21 and associated Technical Notes   

A link to Schedule 2 of the 2008 Order can be found below: 
UK Strategic Export Control Lists 

Schedule 3 to the 2008 Order (UK Dual Use Goods, Software and Technology)   

UK Dual Use Category PL9013.a4 – administrative amendments to the Technical Parameters. PL9013 was added to the consolidated list in April 2024 and relates to Integrated Circuits   

 A link to Schedule 3 of the 2008 Order can be found below: 
UK Strategic Export Control Lists 

Annex I to the assimilated Dual Use Regulation 428/2009 (Dual Use Goods, Software and Technology)   

Amendments to Annex I, 428/2009, to reflect routine technical updates to controls implemented by four of five contributors to the Dual Use List: The Wassenaar Arrangement, Australia Group, Nuclear Suppliers Group and Missile Technology Control Regime, which includes definitions to technical notes and several control entries, including: 

• Category 0: 0B004a and 0B004b 
• Category 1: 1A202, 1A225, 1B228, 1C002, 1C005 
• Category 2: 2B352 
• Category 3: 3A002 
• Category 5: 5A001, 5E001, 5A002 
• Category 6: 6A005, 6A225 
• Category 8: 8A001, 8A002 
• Category 9: 9A004, 9B, 9E003       

A link to Annex 1 to the Assimilated Dual Use Regulation 428/2009 can be found below: 
Council Regulation (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items (Recast) 

The Export Control (Amendment) Regulations 2025 (the Regulations) come into force on 20th  May 2025. The amendments will be reflected in an updated version of the consolidated list, which will be republished in due course.   

The Regulations and Explanatory Memorandum to the Regulations can be accessed here: 
https://www.legislation.gov.uk/uksi/2025/532/contents/made 

In addition to the amendments listed, The Export Control (Amendment) Regulations 2025 (the Regulations), also advise changes to fines which may be imposed for certain offences set out in Part 6 of the Export Control Order 2008. Part 6 relates to Offences, Enforcement and Penalties   

NTE 2025 advises an increase to the maximum level of fine that may be imposed under the 2008 Order for certain offences on summary conviction, from level 3 on the standard scale (£1,000) to level 4 (£2,500), which is confirmed in the Sentencing Act 2020 

Notice to Exporters regularly updates subscribers on settlements relating to unlicensed exports of strategic goods. As recently as February 2025, £3,231,762.40 was paid as a compound settlement to HMRC for unlicensed exports of Military Goods. 

Since February 1st, 2025, the UK Integrated Online Tariff has been updated to reflect changes to Document Codes which may be relevant to your Commodity Code. The recommendation is to check the Export Tab of the Commodity Code to confirm the controls that could apply to your goods. Under Strategic Controls, EX001 means potential control under the Export Control Order 2008, and EX005 is a signpost to a potential control under Regulation 428/2009, the Dual Use control. 

When providing instructions to your forwarder or carrier, it must be confirmed that the goods are licensable and that they are declared in CDS Data Element 2/3. However, if a control doesn’t apply, it is advisable to confirm this on your commercial documentation by declaring “No Licence Required” In addition, if EX001 and/or EX005 relate to your Commodity Code, declaring that a licence isn’t required has extra emphasis. By declaring that a licence isn’t required, with the appropriate document code, the Tariff confirms the exporter is making “a legal declaration that the consignment does not require an export licence” Being able to support this decision with evidence is a requirement if challenged by HMRC or Border Force. “Sufficient evidence must be held in records to demonstrate eligibility for this exemption and must be produced on demand.” 

Many exporters use a third party to complete their Customs Declaration and work with the entity under “Direct Representation.” Due Diligence for Customs and Export Control requirements has increased with the implementation of new changes, and Exporters must be aware of their responsibilities in an ever-changing world of compliance. 

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP: