Upcoming Changes to the UK Strategic Export Control List
The UK government has announced forthcoming updates to the Strategic Export Control List, commonly known as the consolidated list, which encompasses strategic military and dual-use items requiring an export licence from the Export Control Joint Unit (ECJU). These updates align with the UK’s international commitments and reflect recent modifications adopted by multilateral export control regimes.
Key Amendments:
- Wassenaar Arrangement Updates:
- Revisions to control list entries, including ML10, 1C002, 1C005, 3A002, 3C005, 5A001, 5E001, 5A002, 6A005, 8A001, 8A002, 9A004, 9B, and 9E003.
- Editorial Revisions:
- Updates to technical notes and definitions, notably redefining ‘spacecraft’ and introducing specific terms such as ‘satellite’, ‘space probe’, and ‘space vehicle’.
- Nuclear Suppliers Group (NSG) Adjustments:
- Changes to control list entries like 0B004a, 0B004b, 1A202, 1A225, 1B228, and 6A225.
- Australia Group Modifications:
- Revisions affecting entries 1C351, 1C353, 1C354, 2B350, and 2B352.
Legislative Updates:
The Export Control (Amendment) Order 2025 (S.I. 2025 No. 123) will implement these changes, coming into force on 31 March 2025. The updated consolidated list will be accessible on the UK Strategic Export Control Lists page upon the legislation’s enactment.
Action Steps for Exporters:
- Review and Compliance: Thoroughly examine the upcoming changes to ensure adherence to the updated export control requirements.
- Stay Informed: Regularly consult official sources, such as the UK Strategic Export Control Lists page, for the latest information.
- Seek Guidance: For specific queries, contact the ECJU at exportcontrol.help@trade.gov.uk.
Compound Settlement Offer for Export Control Breaches
On March 4, 2025, the Export Control Joint Unit (ECJU) released Notice to Exporters 2025/05, announcing that HM Revenue and Customs (HMRC) issued a compound settlement offer to a UK company totaling £374,326.07 in October 2024. This settlement pertained to unlicensed exports of dual-use goods and the failure to declare a license to customs, as mandated by export license conditions. These violations are contrary to Retained Regulation 428/2009 and Article 38(1)(a) of the Export Control Order 2008. The compound settlement mechanism allows businesses to address specific compliance issues without facing prosecution, provided they meet stipulated conditions. This approach underscores the importance of adhering to export controls and offers a pathway for companies to rectify inadvertent breaches while maintaining compliance. Exporters are advised to regularly review their export control procedures to ensure they align with current regulations, thereby avoiding potential penalties.
North Sea Ship Collision Disrupts UK Trade Routes
A major maritime collision off England’s northeast coast earlier this week involved the Portuguese-flagged cargo ship Solong and the U.S. tanker Stena Immaculate, carrying military jet fuel. One crew member from the Solong tragically died, while 36 others were rescued. The vessel’s Russian captain has been arrested on suspicion of gross negligence manslaughter, with authorities granted additional time for questioning.
Salvage operations are underway, but small fires on the Solong’s top deck remain a concern. The incident could impact UK exporters and importers by causing shipping delays due to route restrictions and potential freight cost increases. Heightened regulatory scrutiny may follow, leading to tighter compliance requirements for vessels operating in UK waters. Insurers may reassess risk, resulting in higher premiums for cargo and vessel insurance.
Businesses should closely monitor shipping updates, maintain communication with logistics partners, and review insurance policies to ensure adequate coverage. Planning contingencies for alternative routes or suppliers will help mitigate potential supply chain disruptions. As investigations continue, UK trade stakeholders must prepare for operational challenges while ensuring compliance with evolving maritime regulations.
For advice or training to help your business keep up with ever changing regulations please do contact us by emailing team@exporter-services.co.uk or clink the link for training courses Import Export Training Courses UK – Exporter Services
