Dual-use goods

What it means

Dual-use goods are goods, software or technology that have ordinary civilian uses but could also serve military purposes, the production of weapons of mass destruction or human rights abuses. Examples include certain chemicals, machine tools, drones, encryption software and electronic components.

Exporting such items from the EU, as well as some intra-EU transfers, brokering and technical assistance, requires authorisation. The list of items is set by the EU export control regulation, and in Slovakia licences are issued by the Ministry of Economy.

A licence may also be needed for items not on the list if the exporter knows, or is informed by the authorities, that they may be intended for a prohibited use. This is known as the catch-all clause and obliges exporters to know their customers.

How it works in practice

For clients exporting technical products, we check whether the goods are listed by comparing their technical parameters with the control lists. The TARIC code also helps, as for many items it flags a possible export control.

Part of compliance is vetting the customer and end user: KYC, sanctions screening, an end-use statement and attention to red flags such as an unusual route, cash payment or a customer with no obvious connection to the goods.

For licensed exports we ensure the licence number and item details are correctly stated in the customs declaration, and we keep the documents for the statutory period.

What to watch out for

Exporting without a licence is a serious offence and in some cases a crime. Heavy fines, confiscation of the goods and export bans may follow. Not knowing the list is no excuse; the exporter is responsible.

Controls do not apply only to physical goods. Emailing technical documentation, making software available through the cloud or training foreign technicians can also be an export of technology requiring a licence.