Import and Export Solutions

Export Licensing // Aircraft Controls

Import & Export Solutions specialises in controls relating to aircraft – these controls are covered in our training packages and workshops.

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1. In the UK

In the UK, export controls are administered by the Department for Business Innovation & Skills, in consultation with the following other government departments:

There are two combined control lists to consider:

  1. Military, security and para-military goods, software and technology and arms, ammunition and related material
  2. Dual-use items and technology

Detailed information can be found in the UK strategic export control list (PDF) from the Department for Business Innovation & Skills:

2. In the US

In the US, there are several departments dealing with export issues. The main ones are:

3. Differences between the UK and US

It is important to note the differences in interpretation and implementation by the UK and US governments, for example:


In the UK if an item was specially designed or has been modified for military use then it will remain military even if subsequently used for civil purposes.

In the US the control lists have been subject to a review and consequently, not all items ‘specially designed or modified for military use’ are controlled under the ITAR. Items removed from the ITAR have transitioned to the EAR under a new ‘600 series’. Some of these 600 series are now only controlled to Cuba, Iran, North Korea, Sudan and Syria.


  1. Under the UK military list, aircraft, aero engines and specially designed components fall under ML10 with electronics falling under ML11.
  2. Under ITAR, aircraft enumerated and specially designed components fall under category VIII, aero engines enumerated fall under category XIX and electronics enumerated falling under category XI. Other items ‘specially designed or modified for military use fall under ‘600 series’ on the EAR.
  3. ITAR controlled items never lose their identity and are controlled ad infinitum.
  4. EAR controlled items are subject to US re-export controls and may need a US license in addition to one from the UK.

Disclosure of US ‘defense articles’ (hardware, software or technical information) to non-US nationals is viewed as an export so nationalities of employees, contract staff and visitors need to be authorised.


Conversations relating to US projects require authorization and, this may be before a contract exists.


Civil aircraft are controlled to certain destinations i.e. military end-users in embargoed destinations and under UK legislation, to commercial operators in Iran but under US legislation, to military end-users in China, Russia and Venezuela and commercial operators in Cuba, Iran, North Korea, Sudan and Syria.


Some commercially available seals and gaskets, avionics and propulsions systems (including technology) are also controlled; this is because some of this equipment can be used or adapted for use in connection with weapons of mass destruction e.g. missile systems.


The US has created additional classification numbers that do not appear in any other country’s control lists. If an aircraft part does not fall under the UK/EU control list then, this same part would most likely be 9A991.d in the USA. Even desks and chairs are classified as EAR99 and are subject to control under the EAR and OFAC e.g. to Cuba, Iran, North Korea, Sudan and Syria.


All of this creates confusions for UK companies since US interpretation can be contrary to UK and EU legislation.

Import and Export Solutions specialises in controls relating to aircraft – these controls are covered in our training packages and workshops.

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> Did You Know?

In the UK if an item was specially designed or has been modified for military use then it will remain military even if subsequently used for civil purposes.

In the US the control lists have been subject to a review and consequently, not all items ‘specially designed or modified for military use’ are controlled under the ITAR. Items removed from the ITAR have transitioned to the EAR under a new ‘600 series’. Some of these 600 series are now only controlled to Cuba, Iran, North Korea, Sudan and Syria.

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