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Export Control and Sanctions: New Export Control licensing requirement applying to exports of emerging technologies

In this blog post, Alan Campbell, Research Integrity Manager in Edinburgh Research Office, outlines a significant recent amendment to the UK export licensing regime. 

About Export Control and Sanctions regimes

Export Control and Sanctions regimes are legal frameworks that exist in many countries worldwide, including the UK, to regulate the export of sensitive or strategically important goods, software and technology.  The specific goods, software and technology controlled by the UK’s export control regime are described in detail in the UK Strategic Export Control List, a government publication which is accessible online and updated periodically.

If an item appears on the Export Control List, then an export licence is required to send it to any recipient overseas.

Individual researchers are legally responsible for their exports, and failure to obtain the required licence can result in prosecution and criminal penalties.

New export licensing requirement

On 1 April, the UK government updated the UK Strategic Export Control List, introducing a new export licensing requirement applying to exports of certain emerging technologies to any destination outside the UK.  The change affects specific goods, software and technology in the following fields:

  • quantum technologies
  • cryogenic technologies
  • semiconductor technologies
  • additive manufacturing equipment
  • advanced materials

Guide to the changes

Edinburgh Research Office has produced a summary guide to help colleagues working in these fields to identify the goods, software and technology that now require export licences to send overseas.  You can access the summary guide from our ERO Export Control webpages:

Light-touch Export Licence

A light-touch Open General Export Licence (OGEL) is available for exports of affected items to the following countries:

  • EU Member States
  • Australia
  • Canada
  • Iceland
  • Japan
  • New Zealand
  • Norway
  • Switzerland and Liechtenstein
  • The Channel Islands
  • USA

Securing licences for exports to these OGEL countries is generally quick and easy.

Alternative licences are available for exports to other countries: these involve more time and paperwork, however Edinburgh Research Office is here to support you.

Export Control: Key definitions

Export: for the purposes of export control, the definition goes well beyond the obvious example of sending physical materials by post or courier to a recipient overseas.  Physical transfer of controlled software or technology (e.g. stored on a laptop or USB stick), electronic transfer of controlled technology or software (e.g. by email or messaging app), oral transmission of controlled information (e.g. by telephone, or video conferencing platform), or allowing an overseas partner to access controlled software or technology stored on a UK server in the Cloud are all activities that can constitute an export and require an export licence.

Software: a collection of one or more “programs” or ‘microprograms’ fixed in any tangible medium of expression.  Microprogram’ means a sequence of elementary instructions, maintained in a special storage, the execution of which is initiated by the introduction of its reference instruction into an instruction register.

Technology: specific information necessary for the development, production or use of goods. This information takes the form of ‘technical assistance’ or ‘technical data’.  ‘Technical assistance’ may take forms such as instructions, skills, training, working knowledge and consulting services and may involve the transfer of ‘technical data’.  ‘Technical data’ may take forms such as blueprints, plans, diagrams, models, formulae, tables, engineering designs and specifications, manuals and instructions written or recorded on other media or devices such as disk, tape, read-only memories.

Further Information

For information and advice on whether your research is affected, or for help in applying for an Export Licence, please contact us at



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