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Exporting electrical and electronic products from the EU

Electronics leave the EU through the standard export procedure, with an EORI number and an export declaration in AES. Items on the EU dual-use list need an export authorisation, and sanctions restrict electronic components to Russia. Batteries, switches and lamps above set mercury limits cannot be exported.

Updated · Each section links to the official source it comes from

Export controls
Regulation (EU) 2021/821 on dual-use items
Authorisations
EU general, national general, global or individual
Sanctions
Russia: dual-use and advanced technology items, electronic components
Mercury
Export ban on listed batteries, switches, relays and lamps
Declaration
Electronic export declaration in AES, with an EORI number

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Is the product, or a component or its software, on the EU dual-use list, or caught by an end-use control? Read more
  2. 2Is the destination or end user subject to sanctions? Read more
  3. 3Does it contain a battery, switch, relay or lamp above the mercury limits? Read more
  4. 4Which certificates and test reports does the destination accept? Read more
  5. 5Does it meet the agreement's list rule, and what proof of origin goes with it? Read more
  6. 6Who lodges the export declaration, with any licence? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Dual-use export controls

The EU regime for goods, software and technology that can have both civil and military uses.

  • Regulation (EU) 2021/821 governs the EU's export controls on dual-use items: a common EU control list in Annex I, common authorisation types, and controls on brokering, technical assistance and transit.
  • Items not on the list can still be caught by end-use controls, for example where they could be used in connection with a weapons of mass destruction programme or for human rights violations.
  • There are four types of authorisation: EU General Export Authorisations (EUGEAs), national general export authorisations, global licences, and individual licences, the last two granted by competent authorities to one exporter.
  • The EUGEAs include ones for exports to Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland, Liechtenstein, the UK and the US, and for telecommunications and encryption.
  • Exporters must keep records and registers. The Regulation applies directly, but member states set enforcement and penalties, and may add controls on non-listed items for public security or human rights reasons.
  • The Commission updates the control list in Annex I by delegated regulation; the latest update was adopted on 14 September 2026.

How we help: Compliant Always keeps your classification against the control list, and any authorisation, with the products and shipments they cover, and watches the list for updates. Ask about this

Export restrictions, licences and sanctions

Goods and destinations that need an export licence or cannot be exported at all.

  • Access2Markets says the export of some goods, or exports to certain destinations, may be prohibited or restricted and need a licence; check TARIC for export licences and the EU Sanctions Map for restrictions.
  • Restricted or prohibited types include some live animals, meat and plants, certain food products, dangerous chemicals, drugs and medicines, dual-use goods, waste, cultural goods and counterfeit goods.
  • Member states may exceptionally have national restrictions, which are checked with their competent authorities.
  • The export procedure includes presenting export licences, and an oral declaration is not allowed for goods subject to prohibitions or restrictions.
  • EU sanctions on Russia (Regulation (EU) No 833/2014) prohibit exports of listed goods and oblige operators to contractually prohibit the re-export of certain sanctioned goods.
  • For Russia, the prohibited exports include dual-use goods and advanced technology items that can contribute to its defence and security capabilities, such as advanced semiconductors, electronic components and software.

How we help: Compliant Always keeps any licence with the shipments it covers and shows when it is near its end, before the next shipment is declared. Ask about this

Mercury-added products: an export ban

Electrical products that the EU prohibits exporting above set mercury limits.

  • The export, import and manufacturing in the EU of the mercury-added products in Annex II to Regulation (EU) 2017/852 are prohibited from the dates given there (Article 5).
  • From 31 December 2020: batteries or accumulators with more than 0.0005% mercury by weight, and switches and relays, apart from narrow measurement and radio-frequency exceptions.
  • From 31 December 2018: compact and linear fluorescent lamps for general lighting above set mercury contents, high-pressure mercury vapour lamps, and cold-cathode and external-electrode fluorescent lamps for electronic displays above set limits.
  • The Commission's mercury page adds that the manufacture and export of six more mercury-containing lamps are banned from 31 December 2025 or 31 December 2026, depending on the type.
  • The ban does not apply to products essential for civil protection and military uses, or for research, instrument calibration or use as a reference standard.

How we help: Compliant Always reads your component declarations for mercury content before a shipment, and keeps them with the product file. Ask about this

Documents for the destination

What the importing country may ask the EU exporter to supply, as Access2Markets sets it out.

    • The destination's health, safety and technical requirements usually fall to the buyer as importer, who will need the exporter's help to show compliance. Access2Markets advises assuming only what the exporter can fulfil.
    • The destination may ask for certificates showing the product meets its health and safety rules, which may differ from the EU's.
    • Check in My Trade Assistant's Procedures and Formalities section which certificates the destination accepts, and whether testing can be done by an accredited laboratory in the EU or must be done in the destination.
    • Destination authorities may also ask for a commercial invoice, packing list, import licence, proof of preferential origin, or a certificate of non-preferential origin.

    How we help: Compliant Always reads your test reports and certificates against what the destination asks for, and answers importers' questions from the record. Ask about this

    Origin and proof of origin

    Preferential origin under EU trade agreements, how it is proved, and certificates of non-preferential origin.

    • To get a lower or zero tariff under a trade agreement, goods must be wholly obtained in the EU or sufficiently worked or processed there under the product-specific 'list rules' of the agreement's origin protocol, read by HS heading.
    • The Commission's Rules of Origin Self-Assessment tool (ROSA), in Access2Markets' My Trade Assistant, helps check a product against the rules and explains which proof of origin to prepare.
    • Proof can be a movement certificate EUR.1 or EUR-MED issued by customs, or a self-declaration by the exporter on a commercial document: a statement on origin, or an invoice or origin declaration.
    • EU exporters must be registered in REX, with their national competent authorities, to make out statements on origin under agreements including those with Canada, Japan, Vietnam, Singapore, the UK, New Zealand and Chile, and the EU-MERCOSUR Interim Agreement.
    • Without a REX number, an exporter may make out statements on origin for consignments of originating products worth up to EUR 6 000 (EUR 10 000 for trade with the OCTs).
    • Suppliers' declarations let an exporter rely on the originating status of materials bought in the EU. Exporters keep copies of proofs of origin and related records for at least three years.
    • A Binding Origin Information (BOI) decision from customs fixes the origin of goods for up to three years, but does not replace the proof of origin.
    • A certificate of non-preferential origin may be required by the destination; Access2Markets says these are usually issued by the local chamber of commerce, and in some countries by ministries or customs.

    How we help: Compliant Always keeps the REX number, suppliers' declarations and each statement on origin or certificate with the shipment it covers, and shows which proofs are missing or out of date. Ask about this

    EORI and the export declaration

    Who may export, the registration number every declaration carries, and the two stages of the export procedure: export and exit.

    • The export procedure (Article 269 UCC) is obligatory for EU goods leaving the EU customs territory, with very few exceptions, so that export measures such as restrictions are applied.
    • An EORI number is mandatory for customs operations in the EU, export included. It is assigned by the customs authority of the member state where the operator is established, and does not expire.
    • Access2Markets says an exporter normally needs to be established in the EU, including a VAT registration; a non-EU resident needs a person established in the EU, such as a logistics provider or customs agent, to act as exporter.
    • The export declaration is lodged electronically in the Automated Export System (AES), at the customs office for the place where the exporter is established or where the goods are packed or loaded (Article 221(2) UCC-IA).
    • It gives the origin of the goods, the destination country, commodity codes, customs procedure codes and the value. Customs may release the goods, ask for documents, or check them physically.
    • The goods and the Master Reference Number (MRN) are then presented at the customs office of exit, which supervises their departure. Goods stay under customs supervision until they leave.
    • Keep invoices, transport documents and packing lists for at least three years. Exports are exempt from EU VAT if records and the customs proof of export are kept.

    How we help: Compliant Always keeps the EORI, invoice, packing list, MRN and proof of exit with each shipment, dated, and shows what is missing before the goods are declared. Ask about this

    Who answers for what

    WhoWhat they answer forHow we help
    ExporterClassifying the goods against the dual-use list, any authorisation, the export declaration and proof of origin.Classification, licences and the declaration kept together for each shipment.
    ManufacturerThe technical data behind the classification, component declarations, and suppliers' declarations for origin.Component and test records kept by product and dated.
    Member state competent authorityGranting global and individual dual-use licences, and enforcing the controls.Each licence kept with the shipments it covers, with its end date shown.
    Customs representative or forwarderLodging the declaration, with any licence, and presenting the goods for export and exit.The documents behind the declaration, ready before it is lodged.

    Member states

    The export rules are EU law, but member states run them. The EORI number, the export declaration, origin registrations such as REX and approved exporter status, and dual-use licences go through the national authorities of the member state concerned.

    Export certificates for food, animal products and plants are issued by member states' competent authorities; the Commission supplies harmonised certificates through TRACES and guidance in its Export library. Certificates of non-preferential origin are usually issued by local chambers of commerce.

    Where are the goods going?

    Most of what electrical and electronic products have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

    Questions businesses ask

    Do I need an export licence for electronics from the EU?
    Only if the item is on the EU dual-use list in Annex I to Regulation (EU) 2021/821, is caught by an end-use control, or is sanctioned for the destination. Otherwise the standard export declaration applies.
    Does encryption in a product need an export licence?
    It can, where the item is on the dual-use list. The EU General Export Authorisations include one for encryption, and one for exports to countries such as the US, Japan, the UK and Canada.
    What is an EU General Export Authorisation?
    An authorisation in Annex II of the dual-use Regulation that lets exporters send certain dual-use items to certain destinations under set conditions, without applying for an individual licence.
    Who grants dual-use export licences in the EU?
    The competent authorities of the member states. They grant global licences, covering several items and destinations, and individual licences, covering one end user or consignee.
    Can I export electronic components to Russia?
    EU sanctions prohibit exports to Russia of dual-use goods and advanced technology items, such as advanced semiconductors, electronic components and software, that can contribute to its defence and security capabilities.
    Can I export batteries containing mercury from the EU?
    Not batteries or accumulators with more than 0.0005% mercury by weight. Their export, import and manufacture have been prohibited since 31 December 2020 under Regulation (EU) 2017/852.
    Can fluorescent lamps be exported from the EU?
    Not those above the mercury limits in Annex II to Regulation (EU) 2017/852, and the Commission says six more mercury-containing lamp types are banned from 31 December 2025 or 2026.
    Are EU test reports for electronics accepted abroad?
    It depends on the destination. Access2Markets advises checking which certificates the destination accepts, and whether an accredited laboratory in the EU can do the testing.
    Do I need an EORI number to export electronics?
    Yes. An EORI number is needed for every export declaration. It is assigned by the customs authority of the member state where you are established.
    How does Compliant Always help with exporting from the EU?
    Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

    Sources

    Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

    Tell us what you make, and we will show you the rules for it.

    Name the product and the markets you sell in. We will come back to you with what applies in the EU and what your paperwork needs to show.

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