Put at its simplest, ‘Rating’ is the process of deciding whether a licence from the Export Control Organisation (ECO) is needed to export particular military or dual-use goods. For many products described in what are known as the UK Strategic Export Control Lists there will be little or no uncertainty, eg firearms, but others will need detailed consideration.
This section outlines:
If you aren't sure whether a licence is needed you can send a rating enquiry to the ECO’s Technical Assessment Unit (TAU) asking them to rate your goods. The Rating Enquiry Advice Service is provided by the Government to assist exporters in making responsible exports.
The service is free but you should bear in mind that it is limited to a maximum of 4 items per enquiry and that multiple applications or enquiries with more than 4 items are likely to be rejected.
TAU is made up of a team of engineers and scientists, all with industrial experience, who provide advice to exporters and other parts of Government on the technical application of the export control legislation.
NOTE: ECO is responsible for issuing export licences for military or so called dual-use goods. For other goods see Export Controls not administered by ECO.
The goods on the enquiry will need to be described in some detail so that TAU can determine whether an export licence is required.
‘Spares’, ‘kits’ and ‘accessories’
Vague descriptions of categories of goods such as ‘spares’, ‘kits’ or ‘accessories’ are insufficient and TAU will usually require a complete breakdown of the goods to be exported in order to provide rating advice. You need to read the document on Supporting Technical Information for more details (see link in right hand column).
Supporting information
Depending on the goods involved, you should provide some, if not all, of the following information when making an enquiry:
In the case of a project, contract or transaction involving numerous exports or transfers, we also need a written overview describing exactly what is being exported, to whom, and when. It should make clear the overall purpose and scope of the project and contain a comprehensive list of the goods and technology involved.
In any event, a simple description of the goods and their capability and potential uses – in non-technical language – is necessary as the application is likely to cross the desks of non-technical personnel in several Government departments and they may have little knowledge of your business.
Export control legislation
UK export control legislation covers military and dual-use goods, as well as other goods that are not controlled for strategic reasons, but may be controlled by either the Weapons of Mass Destruction (WMD) or military end-use control.
So that TAU can make an assessment against what is known as the UK Military List (part of the UK Strategic Export Control Lists) it needs to know whether or not the goods have been specially designed or modified for a military application, as well as the details of that application. While some design or modification intentions are obvious – a fighter aircraft or naval frigate – others are less so. For instance, the addition of a NATO towing hook to a standard family car would modify that car for a military use, regardless of the actual end-use.
If the goods are not specially designed or modified for military use, TAU next considers the UK and EC Dual-Use lists (also part of the UK Strategic Export Control Lists). Dual-use goods are those which are not designed for military use but which could be used in military applications – or are other goods which could be used in the production of military items. This is typically based around the technical performance of the goods. For example, with certain machine tools like lathes, the dual-use list specifies accuracy, how many axes it has and so forth.
If the goods are not included in either the Military or Dual-Use lists an export licence may still be required because of the WMD or military end-use control. Additionally, if you have assessed or previously been advised that your goods do not ordinarily require a licence, but are unsure about the bone fides of the end-user, you should include just one item of the goods in the enquiry to avoid TAU having to make unnecessary assessments.
Where the goods are components of a system, you need to describe the system itself in as much detail as possible by type, model and function. TAU also needs to know whether the components are fulfilling their original design function, or have been modified to meet the purpose of the export.
If, after having considered the goods you wish to export against the current UK Strategic Export Control Lists, you decide you would like TAU to provide rating advice you must use SPIRE to submit your request.
If you have previously sent in an enquiry for the same goods, it would be helpful if you could add TAU’s reference number and that any supplementary information requested at the time of the original enquiry is also supplied.
Our advice will be based on the information you supply. ECO advice does not relieve you of legal responsibility for complying with export control regulations. If you give us incomplete, misleading or false information it could mean that you receive incorrect advice.
Alternatively, if you prefer you can also use self-rate your goods by either checking the UK Strategic Export Control Lists or by using the Goods Checker website. This facility enables you to search the Control Lists by keyword.
Technical Assessment Unit
Export Control Organisation
Updated: 17 April 2008