Catch-all provisions: a nightmare for exporters ? The EU's export control regime on dual-use items is currently built on:
common export control rules, including a common set of assessment criteria and common types of authorisations (individual, global and general authorisations);
a common EU list of dual-use items;
However, there are also common provisions forend-use controls on non-listed items which could be used e.g. in connection with a WMD programme or for human rights violations. In certain cases, EU Member States may introduce additional controls on non-listed dual-use items because of public security or human rights considerations. The implementation of these "catch-all" provisions for non-listed dual-use items is requiring from exporters constant vigilance and a deep knowledge of their customers and end-use of their products.
To help exporters in their due diligence, RespectUs is starting next week a series of articles on catch-all. Stay tuned.