On 25 June 2026, the UK’s Export Control Joint Unit (“ECJU”) introduced a new Open General Export Licence for dual-use items (“Dual-Use OGEL”) intended to simplify licensing requirements for UK exporters of dual-use items by providing a single, streamlined licensing process for exports to certain low-risk destinations. The Dual-Use OGEL entered into force immediately upon its publication.
The Dual-Use OGEL consolidates two existing licences (the EU Member States Dual-Use OGEL and General Export Authorisation (GEA) GEA001) (the “Existing OGELs”) into a single framework, while expanding the destinations in scope by extending licensing coverage beyond destinations already covered by the Existing OGELs (including EU Member States, the United States, Australia, Canada, Iceland, Japan, Liechtenstein, New Zealand, Norway and Switzerland) to include:
- British Overseas Territories;
- Chile;
- Singapore;
- South Korea; and
- Uruguay (the “New Destinations”).
Subject to certain exceptions, the Dual-Use OGEL applies to the export of a wide range of dual-use items listed in Annex 1 of:
- the assimilated Council Regulation (EC) No 428/2009 (for items in England, Wales and Scotland); and
- Regulation (EU) 2021/821 (for items in Northern Ireland).
Additional exceptions apply to exports of certain items to the New Destinations, including but not limited to:
- full face masks, filter canisters and decontamination equipment designed or modified for defence against biological agents, radioactive materials, chemical warfare agents or riot control agents;
- protective suits, gloves and shoes, specially designed or modified for defence against biological agents, radioactive materials or chemical warfare agents;
- body armour;
- software specifically designed or modified for the generation, command and control, or delivery of intrusion software; and
- technology for the development of intrusion software.
Before relying on the Dual-Use OGEL, exporters must register online via SPIRE. In its Notice to Exporters, ECJU has instructed exporters who are registered for the Existing OGELs to register for the Dual-Use OGEL moving forward. ECJU has not indicated that the Dual-Use OGEL will replace the Existing OGELs, and it has not revoked either of the Existing OGELs, but its instruction indicates that this may be the plan, perhaps with a transition period during which both the Dual-Use OGEL and the Existing OGELs will be available for use.
Upon registering for the Dual-Use OGEL, exporters must specify where records of relevant exports or transfers will be kept and where the ECJU may inspect them. In addition, use of the Dual-Use OGEL is conditional upon certain record-keeping requirements outlined in the licence being met, including a four-year retention period for certain documents. Failure to comply with the licence conditions can result in suspension of an exporter’s ability to rely on the Dual-Use OGEL.
