“Robust export compliance mechanisms – complimented by coordinated and efficient internal policies and practices – underpin the ability of exporters to engage in successful cross-border trade. An awareness of key regulatory changes on the horizon in 2016 is more important than ever, in the context of a constantly shifting geo-political landscape, a number of developing sanctions regimes and a myriad of legislation applicable to dual-use goods.”
Emily Jones, Partner, Osborne Clarke
16 March 2016 – Funding for border security
The government’s 2016 Budget confirmed that the Home Office will receive £31 million of funding to form a dedicated group of border officers and intelligence officials to enhance security at UK borders. This is intended to further increase the seizure of non-compliant shipments.
8 April 2016 – Release of exporter information
HMRC is starting to publish by default (on its trade statistics website available here) information relating to exporters of goods from the UK to non-EU countries and the goods (which may include dual-use goods) they export, including:
- the exporter’s name and address;
- the relevant commodity code and a description of the commodity code covering the goods; and
- the month and year of export.
HMRC believes that this initiative will facilitate trade, boost UK growth and help exporters to find new markets.
HMRC will not, however, publish national strategic or sensitive information, nor commercially sensitive information.
Exporters can “opt-out” from having their information published, at any time, by contacting HMRC direct (at: email@example.com).
July 2016 – UK Strategic Export Controls Annual Report 2015
The government will publish the UK Strategic Export Controls Annual Report 2015 in July 2016. This report will cover the UK’s export control policy and practice during the period January 2015 to December 2015.
31 July 2016 – Russian economic sanctions
On 21 December 2015 the European Council extended the economic sanctions imposed on Russia until 31 July 2016 to enable the Council to further assess the implementation of the Minsk agreements (ceasefire arrangements agreed upon by the leaders of Ukraine, Russia and pro-Russian separatists on 5 September 2014 and 12 February 2015).
The economic sanctions include, among others, a prohibition on the supply of dual-use items which are or may be intended for military end-use or for a military end-user in Russia.
Q3/Q4 2016 – EU review of export control policy
The European Commission has for several years been engaged in an extensive and on-going consultation on the future of the European dual-use export control system.
As part of the latest impact assessment phase of this review, and following an online public consultation and export control policy review conference during 2015, the European Commission is expected soon to present its Impact Assessment Report to the European Regulatory Scrutiny Board.
This report, and the wider impact assessment phase, will enable the European Commision to identify the most suitable actions and to prepare a proposal for amendments to the EU Dual Use Regulation (Regulation (EC) No 428/2009) during the course of 2016.