Guide · EU · US · UK

How trade compliance works.

Trade compliance starts with export controls, which decide which goods, software, technology and services can leave a country, where they can go and who can receive them. Sanctions add restrictions on countries, sectors, companies and people. Three frameworks often apply to the same transaction, and every export passes through the same six questions.

What a classification looks like

6A008
Radar systems, EU and US dual-use
5A002
Encryption items
ML11
Military electronic equipment
USML XI
US military electronics, ITAR
EAR99
Subject to US rules, not listed
EU001
Union general export authorisation

The three frameworks

One transaction, up to three sets of rules.

Dualis starts from the EU framework and adds the US and UK layers wherever they apply to your goods, your people or your money.

EU

European Union

Dual-use items
EU Regulation 2021/821, applying directly in every member state.
Military goods
Controlled nationally under the EU Common Military List and Council Common Position 2008/944/CFSP.
Sanctions
EU sanctions bind every EU company and national, wherever they operate.
Licensing
By member states. In Belgium, by the regional authorities of Flanders, Wallonia and Brussels-Capital.
US

United States

Dual-use and less sensitive military items
Export Administration Regulations (EAR), administered by BIS.
Defence articles and services
International Traffic in Arms Regulations (ITAR), administered by DDTC.
Sanctions
Administered by OFAC.
Reach
US rules follow US-origin goods, software and technology worldwide, and can reach non-US products through US content or technology.
UK

United Kingdom

Controls
Export Control Order 2008 and the UK Strategic Export Control Lists: the UK dual-use list and the UK Military List.
Licensing
Export Control Joint Unit (ECJU).
Sanctions
OFSI for financial sanctions, OTSI for trade sanctions.
Since Brexit
Dual-use trade between Great Britain and the EU needs authorisation in both directions.

The six questions

Every export passes through the same six questions.

Each step builds on the one before. A wrong classification makes every later check unreliable, and a good check that nobody repeats protects nothing.

Show requirements for
  1. What is it?

    Classification

    Identify whether your product, software or technology is controlled, and under which list entry.

    EUIs it listed in Annex I of the Dual-Use Regulation, or on the Common Military List?
    USIs it subject to the EAR or ITAR, and what is its ECCN or US Munitions List category? Does US-origin content bring a non-US product under US rules?
    UKWhat is its rating on the UK lists? They no longer automatically follow EU updates, so the answer can differ.
    Dualis service · Classification →
  2. Where is it going, and for what?

    Destination and end-use assessment

    Embargoes and sanctions can ban goods by customs code, and diversion through third countries is a top enforcement priority in all three frameworks.

    EUMost dual-use items move freely within the EU, except the most sensitive ones in Annex IV. Outside the EU, catch-all rules can require a licence even for unlisted items, depending on the end use.
    USLicence requirements depend on the item and the destination, with end-use and end-user controls on top.
    UKSimilar end-use controls apply, together with UK trade sanctions by destination.
    Dualis service · Screening →
  3. Who is involved?

    Party screening

    Screen customers, consignees, end users, intermediaries and banks, including companies owned or controlled by listed persons, and UN lists in every case.

    EUThe EU consolidated sanctions list.
    USOFAC's SDN list, and the Entity List and other BIS lists.
    UKThe UK sanctions list.
    Dualis service · Screening →
  4. Is it authorised?

    Licences

    Check first whether a general or open authorisation covers the export. If not, obtain the right licence, then use it within its conditions.

    EUUnion general export authorisations (EU001 to EU008), national general authorisations, or an individual or global licence from the member state.
    USEAR licence exceptions or BIS licences; ITAR licences and agreements from DDTC.
    UKOpen general export licences, or individual licences from the ECJU.
    Dualis service · Export licences →
  5. Can you prove it?

    Records and reporting

    Keep a complete record of every decision, file what each authority requires, and be ready for an audit. General and open licences come with their own registration and reporting duties.

    EUThe Dual-Use Regulation requires records to be kept for at least five years.
    USEAR and ITAR records must be kept for at least five years.
    UKUK rules set their own retention period and reporting duties for open licences.
    Dualis service · Records & audit →
  6. Does it happen every time?

    Procedures and internal compliance programme

    The first five steps protect you only if your teams follow them on every order, shipment and technology transfer. Dualis drafts your written procedures and internal compliance programme, ready for management sign-off:

    • Compliance policy signed by management
    • Manual setting out roles and responsibilities
    • Procedures for classification, screening and licensing
    • Procedures for shipment holds and record-keeping
    • Templates and checklists for day-to-day use
    • Training for each team, and a yearly review
    EUBuilt on the EU's guidance (Commission Recommendation 2019/1318). A programme is required for EU global licences.
    USAligned with BIS, DDTC and OFAC compliance programme guidance.
    UKAligned with ECJU expectations, which matter especially for users of open licences.
    Dualis service · Procedures →

One adviser for all six steps.

Dualis covers every step across the EU, the US and the UK, so you get one consistent answer instead of three separate ones.

Book a free 30-minute callTake the assessment

General information, not legal advice. Regulatory references change often and should be checked before being relied on.