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Exporting electrical and electronic products from the UK

Electronics that use encryption are typically on the dual-use list, but the Cryptography Note releases mass-market consumer items such as smartphones, routers, smart TVs and games consoles from that control. The exporter checks each item against the UK Strategic Export Control Lists, end-use controls and sanctions; exporting a controlled item without a licence is a criminal offence.

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

Licensing body
Export Control Joint Unit (ECJU), DBT
Control lists
UK Strategic Export Control Lists, dual-use categories 3 to 5
Encryption
Cryptography Note (Note 3) can release consumer items
Licence types
Open general licences, SIELs and other licences
Russia
Ban on domestic electronics over £630 and AV equipment over £840
Customs
Export declaration on CDS, licence declared

Before the goods leave

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

  1. 1Is the item, its software or technology on the UK Strategic Export Control Lists? Read more
  2. 2If it uses encryption, does the Cryptography Note release it? Read more
  3. 3Is there a concern about the end use or end user? Read more
  4. 4Is the destination under sanctions or an embargo? Read more
  5. 5Is the licence, if any, declared on CDS, and is proof of origin needed? Read more

The rules, by area

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

Strategic export control lists

The consolidated list of military and dual-use items that need an export licence.

  • Dual-use items are goods, software and technology that can be used for both civil and military purposes; they fall in categories including 3 electronics, 4 computers and 5 telecommunications and information security.
  • It is the exporter's responsibility to check whether items need an export licence, using the consolidated list, the OGEL and goods checker tools or the control list classification service in SPIRE.
  • A licence is needed to export controlled dual-use items from Great Britain; an open general export licence covers dual-use exports from Great Britain to EU member states.
  • In Northern Ireland, Regulation (EU) 2021/821 applies, and no licence is needed to export controlled dual-use items to the EU.
  • Controlled goods taken out temporarily, including for trade shows, repair or as samples, also need a licence.
  • Exporting controlled items without the correct licence is a criminal offence, with penalties up to a fine and 10 years' imprisonment.

How we help: Compliant Always keeps each product's control list assessment, with its date and the list version, and shows when a notice to exporters changes the list. Ask about this

Encryption and the Cryptography Note

How consumer products with encryption are released from Category 5 Part 2 control.

  • Products that use cryptography are typically controlled under the dual-use list, Category 5 Part 2 (information security).
  • Note 3a releases items generally available to the public from retail stock, whose cryptography the user cannot easily change, and which users can install without substantial supplier support.
  • Examples commonly released include consumer smartphones, consumer operating systems, broadband routers, smart TVs, games consoles and PC components such as CPUs and graphics cards.
  • Note 3b releases components such as wifi chips or GSM modems designed for an existing Note 3a item, where information security is not their primary function.
  • Using public algorithms such as AES or open-source libraries does not by itself remove a product from control, and a released item can still be caught by other lists, end-use controls or sanctions.

How we help: Compliant Always keeps the Cryptography Note assessment for each product beside its specification, so a change in features shows the assessment to revisit. Ask about this

End-use controls

Controls that can apply to items not on any list.

  • Military end-use controls can require a licence for unlisted items intended for military use in an embargoed destination.
  • The enhanced military end-use control does not apply to consumer goods generally available to the public.
  • Items must not be exported if the exporter suspects, or has been informed, that they might be used for chemical, biological or nuclear weapons.
  • ECJU's end-user advice service in SPIRE can be used where the exporter has concerns.

How we help: Compliant Always keeps the end-user details and any ECJU advice with the shipment they relate to. Ask about this

Sanctions

Destination-based restrictions on electronics.

  • Sanctions under the Sanctions and Anti-Money Laundering Act 2018 apply to the whole UK and can also control dual-use goods; one application can cover both regimes.
  • The Russia sanctions prohibit exports of dual-use goods and listed luxury goods, among other categories.
  • Schedule 3A covers electronic items for domestic use over £630 per item and electrical or optical apparatus for recording and reproducing sound and images over £840 per item.

How we help: Compliant Always shows the sanctions lists that apply to a route beside the shipment, with the source, for the exporter to check. Ask about this

Export declaration, licences and origin

Declaring the export, the licence it relies on, and its origin.

  • The export declaration on CDS includes the certificates and licences that apply; exports under a retained general export authorisation use document code X002 with its reference.
  • If no departure message is sent for goods under a standard individual export licence, the exporter sends form C1602 to tell HMRC the goods left.
  • Under the UK-EU agreement, a television (heading 8528) can originate where non-originating parts are from other headings, such as television parts of 8529.
  • Exporters of controlled goods keep the paperwork that shows who owns the goods.

How we help: Compliant Always keeps the licence, the declaration and the origin working for each shipment together, ready when HMRC or ECJU asks. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ExporterClassifying items against the control lists, holding any licence, the declaration and proof of origin.Assessments and licences kept by product and dated.
ManufacturerThe technical details, including cryptographic functions, that an assessment depends on.Specifications ready for each classification.
Customs agent or freight forwarderDeclaring the licence on CDS and the departure.Licence references from the record.
Export Control Joint UnitLicensing, control list classification and compliance visits.The record behind each licence, ready for a compliance visit.

Great Britain and Northern Ireland

Most export guidance here is written for Great Britain (England, Scotland and Wales). Exporters in Northern Ireland apply to DAERA for export health certificates, do not need one to export to the EU, and follow EU dual-use rules under the Windsor Framework.

An EORI number starting GB is needed to export from Great Britain; moving goods to or from Northern Ireland may need one starting XI.

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 consumer electronics?
Only if the item is on the UK Strategic Export Control Lists, caught by an end-use control, or going to a sanctioned destination. Mass-market products with encryption are often released by the Cryptography Note, but the exporter must check.
Do smartphones and laptops with encryption need an export licence?
Products using cryptography are typically controlled under Category 5 Part 2, but Note 3a commonly releases consumer smartphones, operating systems, routers, smart TVs and games consoles that are sold from retail stock and installed by users.
What is the Cryptography Note?
Note 3 to Category 5 Part 2 of the dual-use list. It releases from control items generally available to the public whose cryptography users cannot easily change and can install themselves, and certain components designed for them.
Does using AES or open-source encryption make my product exempt?
No. ECJU says a product is classified on its own functionality; using a public algorithm such as AES or freely available libraries does not by itself remove it from control.
How do I check if my product is controlled?
Check the consolidated list of strategic military and dual-use items, use the OGEL and goods checker tools, or ask for a ruling through the control list classification service in SPIRE.
Do I need a licence to send dual-use electronics to the EU?
From Great Britain, a licence is needed, but an open general export licence covers dual-use exports to EU member states. From Northern Ireland to the EU, no licence is needed.
Do I need a licence to take controlled equipment to a trade show abroad?
Yes. If the goods are controlled, a licence is needed for temporary exports, including events, exhibitions, trade shows, repair and samples.
What happens if I export without the licence I needed?
It is a criminal offence. Penalties range from revocation of licences and seizure to a fine or imprisonment of up to 10 years. Irregularities should be voluntarily disclosed to HMRC.
Can I export TVs, appliances or audio equipment to Russia?
Not above the thresholds in Schedule 3A to the Russia sanctions regulations: £630 per item for domestic electronic items and £840 per item for sound and image recording and reproducing apparatus.
Who issues UK export licences?
The Export Control Joint Unit, in the Department for Business and Trade. It handles applications for standard individual export licences and registrations for open general licences.
How does Compliant Always help with exporting from the UK?
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 UK and what your paperwork needs to show.

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