Don't forget the relevant export licences and approvals when exhibiting or demonstrating controlled goods overseas. Here's what you need to know about the recent update on the Open General Export Licence (OGEL) for military goods intended for exhibition.
On 15th of May 2024, the Secretary of State issued an update on the OGEL for military goods intended for exhibition. This licence allows the export of specified military items to any country, except 91 restricted destinations, including China, Iran, and North Korea, provided the goods are for exhibition and will be returned to the UK. The licence covers items such as cluster munitions, explosive submunitions, anti-personnel landmines, and explosive bomblets. Detailed restrictions and conditions apply to ensure compliance with security regulations. Full update can be found here.
Conditions and Requirements
Approval for Exhibition:
Exporters must secure written approval for exhibiting the goods from the relevant MOD authorities or via the SPIRE online licensing system for private venture goods.
Exporters must produce documentary evidence of the exhibition approval upon request by UK Border Force.
Export documentation must include a note referencing the OGEL or the SPIRE registration details.
Record Maintenance:
Exporters are required to maintain records of the exports for at least four years and permit inspections by authorized officials.
Compliance and Audits:
Exporters must complete a pre-visit questionnaire before audits and take corrective actions if identified as non-compliant.
Regular updates on exports must be made in the SPIRE system annually.
Security Requirements:
For classified goods, a Security Transportation Plan approval is required from the MOD Defence Equipment and Support Principal Security Advisor.
Interpretation and Definitions
The licence provides specific definitions for terms such as "cluster munitions," "explosive submunitions," and "Customs Free Zone" to ensure clarity in compliance.
Validity
The licence is effective from May 15, 2024. Exporters must re-register if they do not use the licence within any 24-month period.
This new OGEL streamlines the process for UK exporters of military goods, ensuring that exhibitions can be conducted under clear and controlled conditions while maintaining strict compliance with national and international regulations. For further details or to apply for the necessary approvals, exporters should consult the Department for Business and Trade or the MOD's relevant authorities.
Source gov.uk
Do I need a licence?
Many companies are not aware of export control regulations implications for them and do not know how to apply for an export license or how to best manage it going forward hence risking strict penalties and fines.
How can we help?
Greater Manchester Chamber of Commerce can provide general advice on your export control query and bespoke consultation on different aspects of UK export controls outlined below:
In-house and bespoke export control compliance training: We can deliver both in-house and virtual training to your team from general compliance to business process and procedure training.
Managing Export Controls and Sanctions training course – September 2024. See here to register.
Export Control Audit: Internal Business Audit of your Business Management System regarding Export Control compliance. This can be conducted as part of an annual BMS audit schedule or before an Export Control Joint Unit (ECJU) visit/audit.
Export Control Managed Service: Acting as the focal point for all licensing activities on behalf of the client to ensure all export licensing processes are compliant with internal business processes and export control regulations.
Product Codification: Audit and codification of products against the UK Export Control List. Ensuring correct definition and understanding of licensing requirements. This would normally involve an initial site visit to understand and discuss products.
Licence Application: Acting on your behalf to ensure that appropriate licences are applied for in a timely and accurate manner to ensure smooth export of product(s). These can normally be conducted remotely if a product codification visit has been carried our previously.
SPIRE Set up and Management: Set-up of an HMRC SPIRE Account on your behalf, and if required, ongoing account management ensuring Licences are managed through the HMRC licence management system. This can be conducted remotely without the need for a site visit, depending on customers IT requirements.
ECJU Visit Representation: Representing the client during an ECJU Audit. This would normally only be considered where one or more of the above services have been provided.
Exhibiting Soon? An ATA Carnet is a temporary admission document used for goods to be displayed at trade fairs or exhibitions, professional equipment and samples. Greater Manchester Chamber is an authorised agent to issue ATA Carnets and our team has more than 30+ years of experience.
Please email international@gmchamber.co.uk for more information or if you would like to discuss requirements.