On 7 April 2025, the Dutch government announced changes to certain general licenses for transfers of dual-use and military items, as follows:
- National General Export Authorization NL002, for eligible exports of dual-use items to most destinations worldwide, will be repealed in its entirety.
- National General Export Authorization NL010, for eligible exports of encryption dual-use items, will be amended to exclude Israel as an eligible country of destination.
- National General Transit Authorization NL007, for eligible transits of military items through the Netherlands, will be amended to exclude Israel as an eligible country of destination.
These changes will be effective from 8 April 2025. Therefore, operators can no longer rely on these general licenses for transfers that are no longer covered by the respective general licenses because of the above changes. Instead, operators will need to confirm whether another general license is available (requiring a one-off prior registration for use) or apply for transaction-specific licenses (global or individual) for relevant transfers. Record-keeping requirements for transfers that were previously lawfully made under the now amended general licenses remain to apply.
The explanatory notes suggest that these changes are driven by the Dutch governmentās desire to be able to apply increased scrutiny to relevant transactions. This particularly applies in light of geopolitical developments since the introduction of the relevant licenses, several years ago. However, as also noted by the Dutch government, these changes do not mean that transfers that are affected by these changes will no longer be allowed. Therefore, it will still be possible to apply for and, in many cases, obtain transaction-specific licenses for relevant transfers.
