On 20 July 2020, the UK Foreign Secretary, Dominic Raab, announced that the UK will extend to Hong Kong an EU arms embargo that has applied to mainland China since 1989 (the “Arms Embargo”). This extension forms part of the UK Government’s response to the new Hong Kong National Security Law, and the increasing role that the UK Government claims China is exerting over law enforcement in Hong Kong.

The Arms Embargo prohibits the export of the following from the UK to China:

  • lethal weapons, such as machine guns, large-calibre weapons, bombs, torpedoes, rockets and missiles
  • specially designed components of the above and ammunition
  • military aircraft and helicopters, vessels of war, armoured fighting vehicles and other weapons platforms
  • any equipment which might be used for internal repression

Open general licences that include Hong Kong will be changed or amended to bring them in line with restrictions on China.

The exact timing for the extension is not clear. However, while the UK has not yet implemented its own sanctions regime for China post-Brexit, the Arms Embargo will continue to have effect in the UK once the transition period ends on 31 December 2020.


Sven Bates is Of Counsel for International Trade at Baker McKenzie. He has spent the majority of his career at the Firm's London office, focusing on international trade compliance, trade remedies and anti-bribery. He has also practiced in Amsterdam and has previously worked for the European Commission and the Shadow Attorney General. Sven has extensive experience in particular in the financial services sector, and has undertaken secondments at a Tier 1 UK bank and the Lloyd's insurance market.