Do small companies have to observe export control?

Yes – export control applies to all companies regardless of size. Technical goods, software and chemicals in particular are often controlled. Ignorance is no defence.

How do I check whether my goods are subject to export control?

Step 1: determine the HS code and commodity code. Step 2: check the EU dual-use list (Annex I to Regulation 2021/821). Step 3: use the BAFA database and take advice where necessary. Step 4: screen the end user against the sanctions lists.

Export Control: Export Restrictions in Foreign Trade

Export Control: Export Licences and Sanctions Lists

Export control refers to state measures to control and restrict the export of certain goods and technologies on security and foreign policy grounds. In the EU the dual-use regulation governs the export of so-called dual-use goods (usable for both civil and military purposes).

Last updated 21 August 2026 · NexCargo GmbH

At a Glance

EU legal basis: Dual-use Regulation 2021/821
Competent authority (Germany): BAFA
Sanctions lists: EU, UN, US (OFAC)

Dual-use goods: civil and military uses

Dual-use goods are products that can be used both civilly and militarily: electronic components, chemicals, machinery, software and technologies. The EU dual-use regulation (Regulation 2021/821) lists all controlled goods with their HS code and control number. Exporting them to certain countries requires an export licence.

Sanctions lists and embargoed countries

Exporters must screen recipients and end users against EU, UN and US sanctions lists. Embargoed countries (Iran, North Korea and, since 2022, Russia) are subject to strict export restrictions. Sanctions screening should be automated and documented – doing it manually is error-prone and time-consuming.

Consequences of a breach

Breaches of export control rules can carry severe penalties: fines running to several million euros, custodial sentences for those responsible and withdrawal of export licences. BAFA (the Federal Office for Economic Affairs and Export Control) is the competent licensing authority in Germany.

Export Control: Export Licences and Sanctions Lists

At a Glance

Dual-use goods: civil and military uses

Sanctions lists and embargoed countries

Consequences of a breach

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