UK exporters are responsible for establishing whether their goods, software or technology are subject to export controls and for ensuring that any required licence is in place before export. Where such a distinction was unclear, exporters could seek advice from the Export Control Joint Unit (ECJU), the UK government’s export licensing body, through its Control List Classification (CLC) Service.
ECJU paused this service on 12 October 2026 and will not process new requests. That said, exporters remain responsible for determining whether their items are controlled and may now need to rely more on their own expertise or independent advice.
Two days later, ECJU widened several open general export licences (OGELs), which allow registered exporters to make eligible exports without applying for an individual licence. These changes may reduce licensing delays, but businesses must still establish that their items and the proposed export meet the relevant licence’s terms. The wider permissions therefore arrive at a time when official help with that initial classification is less readily available.
The classification service and licensing delays
ECJU introduced the pause to give licence applications priority. It says that increasingly complex cases have made it harder to provide classification advice while processing applications without undue delay. Requests received before 12 October will still be answered, although replies may take longer than usual. ECJU is considering how to provide the service more efficiently and has promised an update before the end of 2026, but has not set a date for it to resume.1
When ECJU restored the service in June 2018, following a four-year suspension for operational reasons, it asked exporters to examine their items against the relevant controls before seeking advice. Its replies relied on the information supplied and did not relieve exporters of their legal obligations. The service offered guidance on an exporter’s conclusions, rather than approval for a particular export.2
The pause comes amid percentages slightly behind target in processing standard individual export licences (SIELs), which ECJU considers case by case. Its target is to process 70% of applications within 20 working days. In the first quarter of 2026, the latest published period, it closed 55% within that time on its older licensing system and 66% on its newer system. ECJU reports the systems separately because their methods differ. Both results fell below the target, providing context for the decision to give licence applications priority.3
Wider open licences
The dual-use OGEL is one of the licences whose scope has been widened. It covers items that can have both civil and military uses. Introduced in June 2026, it combined two earlier general licences and added South Korea, Singapore, Chile, Uruguay and the specified British Overseas Territories. ECJU based that expansion on a review of earlier licensing decisions, which showed that the exports concerned had consistently been approved and presented a low risk.
The October version adds Bahrain, Botswana, Brunei, Jordan, Kuwait, Mauritius, Morocco, North Macedonia, Oman, the Philippines, Qatar and Seychelles. This is therefore an excellent time for any exporters reviewing the dual-use OGEL to see if its expanded scope will be of benefit.
The changes also extend the two OGELs for military goods, software and technology. The broader licence now permits eligible exports to commercial and government/NATO end-users in Switzerland, Liechtenstein, South Korea and 14 EU member states. The licence for government and (where applicable) NATO end users adds Brunei, Chile, Jordan, Kuwait, Montenegro, North Macedonia and Oman. ECJU estimates that the October changes could remove the need for more than 800 SIEL applications each year, allowing its staff to devote more time to sensitive cases.4 For exports that qualify, the practical benefit is less dependence on individual licensing decisions and the delays that may accompany them.
How can we help?
Our International Trade & Foreign Investment Practice advises businesses on the UK controls that apply to their goods, software and technology, and on the licences available for their exports. We work with legal, compliance and technical teams to examine how product specifications relate to the control lists and to resolve questions about classification. We also advise on whether proposed exports fall within an open licence, taking account of the items, destinations and intended uses involved. For businesses considering the use of open licences, we explain how the conditions and exclusions may affect their exports, as well as advising on record-keeping requirements.
1 Export Control Joint Unit, “Notice to Exporters 2026/22: temporary pause of the Control List Classification (CLC) service” (12 October 2026).
2 Export Control Joint Unit, “Notice to exporters 2018/15: control list classification service to return on 25 June” (21 June 2018).
3 Export Control Joint Unit, “Strategic export controls commentary: 1 January to 31 March 2026” (27 August 2026) S 6.
4 Export Control Joint Unit, “Notice to exporters 2026/23: expansion of military and dual-use open general export licences” (14 October 2026).
