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Rating Enquiry Advice

Put at its simplest, ‘Rating’ is the process of deciding whether a licence from the Export Control Organisation (ECO) is needed to export particular goods. For many products described in what are known as the UK Strategic Export Control Lists  there will be little or no uncertainty, eg firearms, but others will need detailed consideration.

If you aren't sure whether a licence is needed you can send a rating enquiry to the ECO’s Technical Assessment Unit (TAU) asking them to rate your goods. The Rating Enquiry Advice Service is provided by the Government to assist exporters in making responsible exports.  The Service is free but you should bear in mind that it is limited to a maximum of four items per enquiry and that multiple-form applications or enquiries with more than four items are likely to be rejected. For details of how to submit a Rating Enquiry, see below.

TAU is made up of a team of engineers and scientists, all with industrial experience, who provide advice to exporters and other parts of Government on the technical application of the export control legislation.

The goods on the enquiry will need to be described in some detail so that TAU can determine whether an export licence is required. 

Supporting information

Depending on the goods involved, you should provide some, if not all, of the following information when making an enquiry:

• The original design purpose, unless  it is reasonably obvious, especially if it differs from the current intended use
• Brochures, data sheets and ‘short form’ descriptions – but not manuals unless they are subsequently requested by us
• Clear information about the type and functions of the goods with the key technical parameters (not just weight and size!)
• Identification of general purpose items with explanations. Examples might be brackets, washers, nuts and bolts, but TAU needs to know what in what application they are being used as components
• Your own preliminary assessment of the good’s ‘Rating’
• Clear information about what the goods are intended to be used for, and by whom, and details of any modifications that have been made.

In the case of a project, contract or transaction involving numerous exports or transfers, we also need a written overview describing exactly what is being exported, to whom, and when. It should make clear the overall purpose and scope of the project and contain a comprehensive list of the goods and technology involved.

In any event, a simple description of the goods and their capability and potential uses – in non-technical language – is necessary as the application is likely to cross the desks of non-technical personnel in several Government departments and they may have little knowledge of your business.

Export control legislation

UK export control legislation (see link in right hand column) covers military and dual-use goods, as well as other goods that are not controlled for strategic reasons, but may be controlled by either the Weapons of Mass Destruction (WMD) or military end-use control.

So that TAU can make an assessment against what is known as the UK Military List (part of the UK Strategic Export Control Lists, see link right hand column) it needs to know whether or not the goods have been specially designed or modified for a military application, as well as the details of that application. While some design or modification intentions are obvious – a fighter aircraft or naval frigate – others are less so. For instance, the addition of a NATO towing hook to a standard family car would modify that car for a military use, regardless of the actual end-use.

If the goods are not specially designed or modified for military use, TAU next considers the UK and EC Dual-Use lists (also part of the UK Strategic Export Control Lists). Dual-use goods are those which are not designed for military use but which could be used in military applications – or are other goods which could be used in the production of military items. This is typically based around the technical performance of the goods. For example, with certain machine tools like lathes, the dual-use list specifies accuracy, how many axes it has and so forth.

If the goods are not included in either the Military or Dual-Use lists an export licence may still be required because of the WMD or military end-use control.  Additionally, if you have assessed or previously been advised that your goods do not ordinarily require a licence, but are unsure about the bone fides of the end-user, you should include just one item of the goods on the form to avoid TAU having to make unnecessary assessments.

Where the goods are components of a system, you need to describe the system itself in as much detail as possible by type, model and function. TAU also needs to know whether the components are fulfilling their original design function, or have been modified to meet the purpose of the export.

‘Spares’, ‘kits’ and ‘accessories’

Vague descriptions of categories of goods such as ‘spares’, ‘kits’ or ‘accessories’ are insufficient and TAU will usually require a complete breakdown of the goods to be exported in order to provide rating advice. You need to read the document on our website on Supporting Technical Information for more details (see link in right hand column).

Submitting a Rating Enquiry

If, after having considered the goods you wish to export against the current UK Strategic Export Control Lists, you decide you would like TAU to provide rating advice, please complete the Export Licence Rating Enquiry Form and send it, along with the relevant supporting information and technical specifications, (faxes are accepted) to TAU at the address below. If you have previously sent in an enquiry for the same goods, it would be helpful if you could add TAU’s reference number and that any supplementary information requested at the time of the original enquiry is also supplied.  Click on the Rating Enquiry form in the right hand column.  It was revised in June 2006.

Please download or photocopy the form for future use.

Our advice will be based on the information you supply. ECO advice does not relieve you of legal responsibility for complying with export control regulations. If you give us incomplete, misleading or false information it could mean that you receive incorrect advice.

Technical Assessment Unit
Department of Trade and Industry
Export Control Organisation
Bay 352, Kingsgate House
66-74 Victoria Street
London SW1E 6SW
 
Tel 020 7215 8012
Fax 020 7215 0680

18 July 2007