Screening Glossary
What are dual-use goods?
Dual-use goods are items, software and technology with civilian applications that can also serve military purposes or weapons of mass destruction. Exporting them normally requires an authorisation from a national licensing authority.
Updated
In the EU, dual-use export controls are set by Regulation (EU) 2021/821, which lists controlled items in its annexes and requires authorisation for their export outside the Union. The list runs from obvious items such as high-grade machine tools and encryption software to unremarkable components with a military application. Two traps recur: the catch-all provisions, which can control an unlisted item where the exporter is aware of a problematic end use, and technology transfer, where emailing a specification counts as an export.
What this workflow covers
- Classify the goods first, then screen the parties. Both have to clear before anything ships.
- A Polish supplier of industrial sensors classifies the item under the EU control list, applies for an authorisation, and screens buyer and end user against sanctions and export-control registers.
- Sharing controlled technology with a colleague or contractor in a third country, or making it downloadable, can be an export even though nothing physical moves.
- The same shipment can be lawful under export control and prohibited by sanctions.
Compliance glossary
- Control list
- The annexed schedule of items whose export requires authorisation, identified by control number and technical parameters.
- Intangible technology transfer
- Transmitting controlled technology or software electronically, orally or by making it available abroad; treated as an export in most regimes.
Authoritative references
Questions
Frequently asked questions
How do we know if our product is dual-use?
By classifying it against the control list annexed to the applicable regulation, in the EU the annexes to Regulation (EU) 2021/821. Classification is technical and specification-driven, so obtain a written classification and keep it in the product file rather than relying on an engineer's recollection.
What are catch-all controls?
Provisions extending control to unlisted items where the exporter has been informed by, or is aware of, an intended use connected with weapons of mass destruction, a military end use in an embargoed destination, or certain other sensitive uses. An item's absence from the list is not the end of the analysis.
Does export-control screening cover our sanctions obligation?
No, they answer different questions. Export control asks whether this item may go to this destination and end user; sanctions screening asks whether these parties may be dealt with at all. Trade-compliance programmes run both.
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