Following the entry into force of the new EU Dual-Use Regulation 2021/821 last month (see also our recent post), the EU has introduced new document codes that need to be used on EU customs export declarations for exports and transits of dual-use items.

Notably, specific codes now apply depending on the relevant (type of) authorisation/licence. The old code “X002” (which was previously valid for all dual-use authorisations) has been replaced and cannot be used anymore. The new document codes are:

Type of authorisationDocument code
Individual export authorisation 
Individual authorisationX060 
Union General Export Authorisation (UGEA) 
UGEA EU001X061 
UGEA EU002X062 
UGEA EU003X063 
UGEA EU004X064 
UGEA EU005X065 
UGEA EU006X066 
UGEA EU007X067 
UGEA EU008X068 
Global export authorisation 
Global authorisationX070 
National General Export Authorisation (NGEA) 
Transit authorisation 
Transit authorisationX072 

As before, the applicable document code needs to be included in box 44 of the Single Administrative Document (SAD), together with other relevant details. Exporters are advised to review the document codes that apply to their authorisations/licences and implement necessary updates, both internally and externally (e.g. vis-à-vis freight forwarders and logistics providers), as appropriate.


Christiaan's practice focuses on competition law and international trade law. He has significant experience in advising on a range of competition law issues, including cartels, abusive conduct of dominant undertakings and merger control. He acts for complainants and defendants in investigations, and represents clients in merger control proceedings before the Dutch Authority for Consumers & Markets (ACM) and EU Commission. Christiaan is also seasoned in dealing with EU export control and trade compliance matters, including dawn raid assistance, conducting internal audits and defending clients in investigations by regulatory authorities.


Derk advises clients on a wide variety of EU, regulatory and competition law matters, including merger control, cartels and vertical agreements. In addition, he advises and assists clients with respect to compliance and enforcement issues relating to EU and Dutch export controls, trade laws and sanctions. Derk has further acted for clients in various compliance investigations, both internally and involving government authorities.