The UK Government published a notice to exporters on 4 August 2020, stating that the Export Control Joint Unit (ECJU) has removed Hong Kong as a permitted destination from 22 open general licences, including:

  • 20 open general export licences (OGELs);
  • 1 open general transhipment licence (OGTL); and
  • 1 open general trade control licence (OGTCL).

In addition, the ECJU has revoked 2 open general licences (one OGEL and one OGTL) where Hong Kong was the only permitted destination.

The affected open general licences cover a range of goods and sectors, from chemicals, cryptographic development, military and dual-use items, to information security items, sporting guns, and anti-piracy.

As a result of these changes, exporters will no longer be able to use the open general licences for exports to or trade with Hong Kong, and will instead need to apply for standard individual licences (SIELs).

These changes follow a previous government notice and announcement by the UK Foreign Secretary, Dominic Raab, on 20 July 2020, stating that the UK will extend to Hong Kong the EU arms embargo that it has applied to mainland China since 1989, and that open general licences including Hong Kong will be changed or amended to bring them in line with restrictions on China. Further details are set out in our previous blog post, which can be viewed here.


Adeel Haque is an Associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.