On 20 March 2020, the Export Control Joint Unit (ECJU) of the Department for International Trade published a Notice to exporters 2020/08: coronavirus (COVID-19) – export licence handling. The notice states that the ECJU is taking measures to ensure minimum disruption to the export licence application process, as well as to the advice they provide.
The ECJU has identified processing applications for strategic export licences as a business-critical operation for the Department for International Trade and believe it is essential that businesses continue to receive the authorisations required to export items of a military and dual use nature.
The business continuity measures put in place include:
- technical assessments;
- end-use checks; and
- reviewing applications against the ECJU licensing criteria.
Communications from the ECJU will continue to be sent via SPIRE, including requests for any further information on individual cases and licence decisions will also continue to be sent via SPIRE in the normal way.
The Ministry of Defence team within the ECJU will also continue to process the following:
- Ministry of Defence Form 680s;
- crown exemptions; and
- open general export licence (OGEL) authorisation letters.
The ECJU’s compliance / inspection programme will continue, although site audits will no longer take place and instead have been replaced by remote audits. Sites that were due to be inspected soon will be contacted so sites must ensure the inspector is able to determine an effective communication methods.
The ECJU advises licence holders to ensure they are able to access records, including supporting documentation, for exports made under the licence(s) held.
As priority is being given to licence processing, the ECJU may have to stop the control list advice service and the end-use advice service during this period.
It is noted that should the ECJU experience significant staff absences, this will likely impact licence processing timescales. Authors: Meera Rolaz and Kevin Nordin.
