Export licence

Definition and objectives

An export licence is an administrative authorisation conditioning the export of certain goods. It aims to control the dissemination of sensitive goods for reasons of:

• National security and non-proliferation
• Foreign policy (embargoes, sanctions)
• Cultural heritage protection
• Natural resource conservation

EU regulatory framework

The main export licensing regimes in the EU are:

• Dual-use goods: Regulation (EU) 2021/821 (nuclear materials, advanced computing technologies, surveillance equipment)
• Military equipment: Common Position 2008/944/CFSP (EU Military List)
• Cultural goods: Regulation (EC) No 116/2009
• Sanctioned products: country-specific sectoral regulations

Procedure

The licence application is filed with the competent national authority. Processing time ranges from a few weeks to several months. Licences can be:

• Individual: for a specific transaction
• Global: for a type of good to one or more countries over a period
• General (EU-wide): pre-defined authorisations for certain goods to certain destinations

Common pitfalls

• Exporting without a licence constitutes a criminal offence subject to severe penalties
• The catch-all clause allows authorities to require a licence even for unlisted goods if the end-use is sensitive
• Intra-EU controls exist for certain goods (digital surveillance technologies)