UK Export Control: Procedures, Risks, and 2026 Updates for the Profession

What You Need to Know

On March 24, 2026, Belgian authorities intercepted a shipment of military components from the United Kingdom bound for Israel, in accordance with strategic export control regulations. UK exporters are required to apply the UK's consolidated list of dual-use and military goods, or face criminal sanctions.

Key Points

• The UK's consolidated list brings together military items (ML1-ML22), dual-use goods, and specific categories related to non-proliferation (chemical, nuclear, biological weapons), as stipulated by the Export Control Act 2002, Export Control Order 2008 and assimilated EU regulations (source: UK Dept Business & Trade, 2026-04-24).
• Freight forwarders must verify whether the goods fall under one of the 22 ML categories on the list (e.g. ML5 – fire control systems or ML10 – components for military aircraft; source: Military.com, April 18, 2026).
• Any unauthorized export exposes the declarant, freight forwarder, or exporter to sanctions, including confiscation, license suspension, or criminal prosecution (source: UK Dept Business & Trade, 2026-04-24).

Context and Issues

For the profession, compliance with the “strategic export controls” framework is based on several texts: Export Control Act 2002, Export Control Order 2008, Regulation (EU) 2021/821 (“dual-use”) and Regulation (EU) 2019/125 on goods usable for capital punishment or torture. In the UK, exemptions and control lists are freely available. Belgium applied its own procedures on the basis of European regulation by detaining an ML5 and ML10 shipment in transit, illustrating customs cooperation in the enforcement of export control rules (source: Military.com, April 18, 2026).

The profession is also observing an intensification of international restrictive measures. For example, on April 24, 2026, China prohibited the export of dual-use goods to 7 European entities involved in arms sales to Taiwan, pursuant to the Export Control Law (source: Reuters, 2026-04-24; Global Times, April 24, 2026).

Impact on the Profession

The declarant, exporter, and freight forwarder must verify the tariff classification, category (ML1-ML22 or “dual-use”), and document every shipment. License applications are processed using the “OGEL checker”, “control list service”, or SPIRE systems. Sanctions may include license revocation, fines, or detention. Risk management is strengthened through internal controls and by obtaining end user statements, limiting the risk of goods being detained or facing prosecution.

The sector must anticipate export controls, including during transit through the EU, as regulatory discrepancies may result in goods being withheld or seized by European customs authorities.

Next Steps

• The profession should regularly consult the UK consolidated list.
• Every shipment of “defence” or “dual-use” items requires a prior check to determine if a license is necessary.
• For EU-UK flows or those transiting through Europe, both EU and national export control rules must be considered until further updates are released.

Le 24 mars 2026, la profession a constate une retention d'une expedition militaire UK en Belgique pour controle export.
(Translation: On March 24, 2026, the profession observed the detention of a UK military shipment in Belgium for export control.)

Source: UK Dept Business & Trade, April 24, 2026; Military.com, April 18, 2026; Reuters, April 24, 2026; Global Times, April 24, 2026