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  • The export and re-export of strategic goods​

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  • Introduction


This guide covers information on the export and re-export of strategic goods.
  • What are strategic goods?

Strategic goods are goods that only have a military use, dual-use goods, weapons of mass destruction (WMDs) and goods used to produce WMDs.
 
Dual-use goods are items that can be used for both civil and military purposes, ranging from raw materials to parts and complete systems. Such goods can also be items used to produce military goods, such as manufacturing equipment and computers.
 
Strategic goods are listed in Federal Law No.13 of 2007 concerning the goods subject to import and export control. If an item is not listed, but you are notified by the Committee for Goods and Materials Subjected to Import and Export Control in writing that the product will be used in a related activity, you must obtain the import/export permit.
  • Exporting strategic goods

If you want to export, re-export (see glossary) or make temporary shipment (see glossary) of strategic goods, you must first obtain an import/export permit from the Committee for Goods and Materials Subjected to Import and Export Control.
 
You must obtain a permit before mediating or negotiating any contract for ownership or sale of any strategic goods, if you know that a contract will result in the transfer of those goods to another country.
  • Non-controlled goods

If you have been advised by the Committee for Goods and Materials Subjected to Import and Export Control that your goods are not listed in the table but are to be used or likely to be used, wholly or partly, for a related activity (see glossary), you may not export, re-export, ship or enter the goods for transit (see glossary).
 
The same applies if you know without being advised that the goods or technology are to be used, in full or in part, for a related activity.
  • Strategic goods technology

You must obtain approval before exporting any documents that contain information on strategic goods technology. This applies to any information you send through electronic means, or make available on computers in the UAE, that relates to any technology for strategic goods that can inform another person outside the UAE.
 
You must get approval to export the technology necessary for installation, operation or maintenance of any commodity exported, shipped or entered for transit. You do not need to get approval for commodities not listed in the table.
 
If you are advised by the Committee for Goods and Materials Subjected to Import and Export Control that the technology used for unlisted items is to be used or likely to be used, wholly or partly, for a related activity (see glossary), you cannot mediate, negotiate or perform any act to help close a contract for the acquisition or disposal of such technology. The same rule applies for publishing any document that contains technology registered or stored in it.
 
If you know, or have reasonable grounds to suspect, that a technology will be used in whole, or in part, in a related activity, you are not allowed to mediate, negotiate or perform any act to help close a contract.
  • Prohibition on publishing, transferring or disclosing any information or documents relating to strategic goods

You must not publish, transfer or disclose any information or documents relating to strategic goods without the written consent of the chairman of the Committee for Goods and Materials Subjected to Import and Export Control.
 
This excludes supplying information or documents to the State at the request of the judicial authorities.
  • Penalties

If you break any of rules in regards to the import and export of strategic goods, you can be imprisoned for a minimum of one year and/or receive a fine of between AED 50,000 and AED 500,000.
 
If you repeat an offence, the penalty will be doubled.
 
If you are convicted, the court will confiscate the goods in question.
 
If you do not get approval, get a license, or inform the Committee for Goods and Materials Subjected to Import and Export Control or licensee of the disposal of strategic goods, you can be imprisoned for a minimum of one year and/or receive a fine of between AED 10,000 and AED 50,000. The same penalty will apply if you do not provide the Committee with any documents or information they request relating to such conduct.
 
If you breach the prohibition on publishing, transferring or disclosing information on strategic goods, you can be imprisoned for a minimum of one year and/or receive a fine of between AED 50,000 and AED 500,000.
 
The same penalty will apply if you give false or misleading information, or pass on documents that contain false or incorrect statements, in order to obtain approval or a license.
  • Further information

This guide is for reference only. For legal advice you should contact a UAE lawyer.

  • Glossary

Re-export
To export goods that have been previously imported into the UAE with customs clearance, or deposited in free zones, warehouses or customs warehouses, where customs duties were not paid.
 
Temporary shipment
Moving goods that haven’t been delivered anywhere in the UAE from the means of transportation that brought them into the UAE and reloading them on the same or another means of transport in order to remove them from the UAE. This must be done under airway bill, sea freight bill of lading or a manifest while remaining under customs and security control.
 
Transit
Movement of goods that haven’t been delivered anywhere in the UAE into and out of the UAE on the same means of transport while remaining under customs and security control.
 
Related activity
The development, production, handling, operation, maintenance, storage, detection, identification or dissemination of any nuclear, chemical or biological weapon. Or the development, production, maintenance or storage of missiles capable of carrying such weapons.
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