UK Introduces Sanctions End‑Use Controls

• As from 13 May 2026, exports from the United Kingdom of goods and technology not listed on the UK Strategic Control Lists to non-sanctioned third countries may require a licence.
• This licence requirement will only apply in situations where the UK government considers there to be a risk of diversion of the goods and technology to a sanctioned country and informs the exporter of such risk.
• To minimise the risk of goods being detained at the UK border, exporters of goods and technology that are at a higher risk of diversion should consider conducting enhanced due diligence and obtain end use undertakings prior to export.

The UK has announced the introduction of a system of end-use controls on certain goods and technology subject to sanctions that parallel similar controls on goods and technology subject to export controls.

The new measures are contained in The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (here), and explained further in the associated Explanatory Memorandum and Guidance (here, here). The measures will come into force on 13 May 2026.

End-Use Controls for Export Controls Purposes

Under the parallel system, goods and technology exported from the UK that are not subject to “classical” export controls (i.e. not listed on the UK Strategic Control Lists, and therefore not automatically subject to licencing on export from the UK) can be subjected to end-use controls at the UK border. These end-use controls apply where the UK government has concerns about the end-use to which those goods and technology might be put and notifies the exporter of those concerns. These end-use controls focus primarily on weapons of mass destruction (WMD) (nuclear, chemical and biological weapons, and systems for their delivery) and military end-use in certain embargoed destinations.

When such goods and technology are presented at the UK border, the UK government detains the goods and technology and requires a licence to be applied for and granted in order for the goods and technology to be exported. In many cases, a licence is not granted. The presentation of the goods and technology at the border is not unlawful, and so the goods and technology are merely detained, but not seized. The goods and technology can be released back to the exporter where it undertakes not to export the goods and technology without applying for an export licence.

End-Use Controls for Sanctions Purposes

The new “sanctions end-use controls” are similar in terms of application but are imposed for a different purpose.

Under UK sanctions measures imposed by the Sanctions and Anti-Money Laundering Act 2018, exports of certain goods and technology that are not listed on the UK Strategic Control Lists can be prohibited “to or for use” in a destination. The most relevant example is Russia and so we will focus on the revised Russia measures. However, the new end-use controls affect all other relevant UK sanctions regimes that impose trade sanctions as well. As of the date of this alert, these include the sanctions regimes targeting Belarus, the Democratic People’s Republic of Korea (DPRK), Iran, Libya, Myanmar, nongovernment-controlled territories of Ukraine, Somalia, Syria, Venezuela and Zimbabwe.

Under Regulation 22(1) of The Russia (Sanctions) (EU Exit) Regulations 2019 (as amended) (Russia Regulations): “The export of restricted goods to, or for use in, Russia is prohibited”.

“Restricted goods” (and mutatis mutandis “restricted technology”) are defined in Regulation 21 of the Russia Regulations as follows:

• Critical-industry goods (as set out in Schedule 2A)
• Dual-use goods
• Military goods
• Aviation and space goods (as set out in Schedule 2C)
• Oil refining goods (as set out in Schedule 2D)
• Quantum computing and advanced materials goods (as set out in Schedule 2E)
• Defence and security goods
• Maritime goods (as set out in Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of the Merchant Shipping Notice 1874).

This prohibition on restricted goods and technology requires exporters from the UK to understand where the restricted goods and technology are in fact going. If the final destination is Russia, then export from the UK is prohibited, even if the goods and technology are initially exported to a country other than Russia.

Until the new measures were introduced, the UK government had no way of stopping or licencing the export, as the goods and technology could lawfully be exported to any third country other than Russia and—with the exception of dual-use and military goods—would not have required a licence for such export. In situations where the UK government suspected specific shipments were at risk of being diverted to sanctioned destinations, His Majesty’s Revenue and Customs, together with the Department for Business and Trade (DfBT), were able to advise the exporter of the risk. However, once advised of the risk, the exporter retained the discretion on whether to continue with the export. The UK, along with other G7 members, therefore issued guidance¹ on due diligence in relation to exports that might be destined ultimately for Russia, and potentially in breach of Regulation 22(1) of the Russia Regulations.

Regulation 55A of the Russia Regulations (as amended), which introduce sanctions end-use controls, states:

(1) This regulation applies where—

(a) a United Kingdom person (“P”) has been informed by the Secretary of State that goods or any technology related to the export of the goods (or both) are or may be intended, in their entirety or in part, for export, transfer or use in Russia, in non-government controlled Ukrainian territory, or to a person connected with Russia, and

(b) the goods or technology in question are subject to this Part and are not for the time being specified in—

(i)Schedule 2 to the Export Control Order 2008, or

(ii)Annex 1 of the Dual-Use Regulation.

(2) Subject to Part 7 (Exceptions and licences), P shall not—

(a) export the goods in question, or

(b) transfer the technology in question.”

Where goods and technology specified in Part 5 of the Russia Regulations are presented at the UK border, and the UK government believes that those goods or technologies may be intended, in their entirety or part, for the export, transfer or use in Russia, those items may be detained there (usually by Border Force). The exporter can then apply to the Office for Trade Sanctions Implementation (OTSI) for an export licence, or it can have the goods and technology returned to it after undertaking that it will not export those goods to that same initial destination without a UK licence. As with the WMD and military end-use controls, presentation of these goods and technology at the border is not a criminal offence.

The UK guidance states that applications will be assessed on a case-by-case basis by the DfBT, working closely with other departments where required. Factors that may be considered include:

• “The nature of the good or related technology and its potential uses
• The diversion risks associated with the customer, route or end-user
• The exporter’s compliance history and due diligence processes
• Any additional intelligence available to [the UK] government”.

While UK exporters are already expected to undertake due diligence as to the final destination of goods and technology, given the breadth of the new system, it will inevitably involve some exporters having to remove goods and technology from detention and, in many cases, imposing a new licencing obligation. OTSI is currently not accepting prior or speculative licence applications for such exports and so exporters must wait until they are informed ahead of shipment, or more likely until the goods and technology are detained and the UK government informs the exporter of that detention.

Compliance with End-Use Controls for Sanctions Purposes

What does appropriate due diligence look like? The UK has provided specific guidance on this (see here). Section 2.2 sets out a list of goods and technology that are at higher risk of being diverted from a third country to Russia. The list includes:

• “A wide range of industrial machinery, plant and laboratory equipment
• Instruments for aeronautical and radio navigation
• Motor vehicles, engines and vehicle parts
• Tractors and self-propelled works trucks
• Mechanical shovels, excavators and shovel loaders
• Centrifugal pumps
• Turbojets, gas turbines and parts thereof
• Machines for crushing or grinding earth, stone, ore or other mineral substances
• Oil lubricants
• Printing inks
• Paints, varnishes, enamels and lacquers
• Heterocyclic compounds containing a pyrimidine ring or a piperazine ring in the structure
• Reaction initiators and catalytic preparations  
• Heat exchange units, industrial type
• Computer monitors, processing units, semiconductor devices, electronic integrated circuits and apparatus for manufacturing these items.”

In relation to a specific subset of high priority goods and technology, referred to as the Common High Priority List (CHPL), the UK guidance also identifies a list of countries that should be the subject of enhanced due diligence (EDD) when CHPL goods and technology are to be exported initially to or through those countries from the UK. As of the date of this alert, these jurisdictions include: 

• Armenia
• China, including Hong Kong and Macau
• India
• Israel
• Kazakhstan
• Kyrgyzstan
• Malaysia
• Serbia
• Thailand
• Türkiye
• UAE
• Uzbekistan
• Vietnam.

Exports of CHPL goods and technology to these countries require EDD, but it would be difficult to treat sales of all restricted goods and technology to these countries as requiring such measures. Therefore, unfortunately, exporters—at least in the short term—may have to deal with incidents of detention.

Ultimately, the introduction of sanctions end-use controls will require all UK exporters of restricted goods and technology not listed on the UK Strategic Control Lists to understand, to the best of their ability, where the goods or technology will finally be installed. To the extent that EDD raises red flags, it may be appropriate for UK exporters to seek specific contractual end-use undertakings prior to export or run the risk that the export is detained at the UK border.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.