您的浏览器禁用了JavaScript(一种计算机语言,用以实现您与网页的交互),请解除该禁用,或者联系我们。 [翰宇国际律师事务所]:英国新的综合两用开放式一般出口许可证: - 发现报告

英国新的综合两用开放式一般出口许可证:

2026-06-29 翰宇国际律师事务所 李辰
报告封面

One licence, expanded permitted destinations and a new customs declaration Europe – June 2026 On 25 June 2026, the UK’s Export Control Joint Unit (ECJU) announced, in Notice to Exporters2026/14, a new, consolidated Dual-Use Open General Export Licence (OGEL) that merges theexisting EU member states Dual-Use OGEL and General Export Authorisation 001 into a singleopen licence, and extends open licence coverage to new destinations: South Korea, Singapore, The statutory Framework Is unchanged What has changed The reform is best understood as export facilitation, nota relaxation of controls. The underlying control lists areunchanged, registration on the SPIRE system remainsmandatory and the conditions attaching to use of openlicences continue to apply. What has changed is thepackaging of permissions: two separate instruments (and UK strategic export controls rest on the Export Control Act2002 and the Export Control Order 2008 (SI 2008/3231), withdual-use goods, software and technology with both civil andmilitary applications, defined in Article 2(1) of the Order andlisted in Annex I to the Assimilated Dual-Use Regulation (EC) An OGEL is a “ready to use” licence with fixed terms, opento any exporter who registers, offering a low friction routefor lower-risk goods to lower-risk destinations. A StandardIndividual Export Licence (SIEL) is exporter-, consignee-and item-specific, and is assessed case-by-case. An OpenIndividual Export Licence (OIEL) is exporter-specific, butcovers multiple shipments of specified goods to specifieddestinations over a period. Registration to use an OGEL binds The additions rest on the UK’s own risk assessment ratherthan that of a multilateral regime, a distinction that mattersfor diversion risk diligence, discussed below. A parallelmeasure, introduced in May, will mean that all relevant OGELswill change in the coming months to add a condition requiringthe licence reference to be entered on Customs Declaration The CDS declaration requirement: The The two predecessor licences The EU member states Dual-Use OGEL, first published in2019 as a “no deal” contingency and most recently updatedon 16 December 2025, permitted the export of Annex I dual-use items from Great Britain to EU member states.3GEA001,the assimilated successor to the EU’s Union General ExportAuthorisation EU001, authorised the export of the bulk of Notice to Exporters 2026/13 introduces a critical operationalconsideration. Registered OGEL and General ExportAuthorisation (GEA) users receive a unique reference in theform GBOGE20XX/XXXXX. In this notice the Export ControlJoint Unit is notifying exporters that all relevant OGELs will beupdated in due course with a condition, which will require the Both are now being folded into one OGEL with a singleregistration and a single Great Britain Open General ExportLicence (GBOGE) reference, and the destination list hasbeen expanded. The permitted and excluded items arenot loosened by the consolidation; rather, the change is Once the condition applies to a given licence, inclusion ofthe reference on CDS becomes an enforcement matterfor HMRC and an incorrect declaration could constitute acriminal offence under section 167 of the Customs and ExciseManagement Act 1979.7Where a freight forwarder declareson the exporter’s behalf, the exporter must supply the correctreference and instruction. The exporter of the goods and any The new permitted destinations South Korea has a free trade agreement (FTA) with the UK,and it is a major dual-use and semiconductor trading partner.Singapore, a leading financial and logistics hub covered by aUK FTA and the UK-Singapore Digital Economy Agreement,operates robust national controls under its Strategic Goods Post-Brexit divergence from the EU The reform widens, rather than narrows, post-Brexitdivergence. The EU’s framework is Regulation (EU) 2021/821,whose Union GEA EU001 covers Australia, Canada, Iceland,Japan, New Zealand, Norway, Switzerland (includingLiechtenstein), the UK and the US.8The UK’s consolidatedOGEL now reaches South Korea, Singapore, Chile, Uruguay A regime-membership reality check The advent of this new OGEL with expanded permitteddestinations does not align directly to membership of the fourmultilateral export-control regimes. The four regimes are theWassenaar Arrangement, the Nuclear Suppliers Group, theAustralia Group and the Missile Technology Control Regime.Of the five new destinations, only South Korea participates The two control lists remain broadly aligned at the Annex I/Wassenaar level, but update on different timetables andthrough different instruments. The EU’s latest emerging-technology update took effect on 15 November 2025, andthe UK’s on 16 December 2025, while Wassenaar itself hasbeen effectively stalled on new dual-use listings since 2022, This divergence means end-use, end-user and diversion-riskscreening remain important, despite expanded options forexport under this new OGEL and the EU will not neces