Given the current political climate, dual use parts are the subject of new EU sanctions. The reason for the sanctions is simple: dual use parts, while normally used for civilian purposes, can also have military applications and can be used in the proliferation of weapons of mass destruction. Because of the current situation in Russia, the EU has placed a ban on exporting military equipment to Russia, and this includes dual use parts.
If you trade in the global marketplace, it’s important to be sure that your shipments are in compliance. Because breach of sanctions is a criminal offense, we wanted to create awareness of this issue before any problems arise. In terms of the products and services that UNICOM Engineering deals with specifically, we believe that our customers should remain unaffected. What the sanctions are specifically saying is this:
- Dual use items to military end users in Russia are prohibited.
- In addition, spare parts for military use items or military end users are prohibited.
- Dual use as defined by the EU in Annex 1 of EC regulation Number 428/2009 states that “This prohibition should not affect the exports of dual-use goods and technology, destined/designated for non-military use or for a non-military end-user.
In the interest of export compliance, it is strongly suggested that shipments of dual use and non-dual use items be separated. As other countries strive for trade compliance, delays in the shipment of dual use parts should be expected. For example, Dutch Customs has announced that all requests for export document approval for shipments containing dual parts will be held. These requests will be forwarded to the Central Service of Import and Export in the Netherlands, and that organization will determine on a case-by-case basis whether or not to issue export documents. As you can imagine, this will result in delays.
These measures taken by the EU are at the forefront of international efforts toward non-proliferation and must adjust as security risks and threats evolve. Regularly holding public consultations and maintaining constant dialogue with industry associations as well as academia and civil society, the European Commission strives to strike a balance between security and competitiveness. You can read the EU’s press release regarding these sanctions here.
UNICOM Engineering will continue to ensure compliance of sanctions and will inform clients of any delays caused by this issue. For a complete list of dual use parts, click here.
Our Global Logistics Services team is fully versed in global trade regulations, and we’re ready to help clients in every way possible. To learn more about UNICOM Engineering’s Trade Compliance capabilities visit our website and connect with us on LinkedIn, Facebook, and Twitter.