What additional obligations are imposed on exporting companies when exporting dual-use goods and what documents must be prepared in order to obtain the appropriate export permit?
The export of dual-use goods is a special area of foreign economic activity regulated by additional rules and obligations. Such goods have properties suitable for both civilian and military purposes, and therefore require special attention from regulatory authorities.
The main obligations of exporting companies
Companies engaged in the export of dual-use goods have the following obligations:
1. Obtaining a special license:
The export of such goods is possible only upon receipt of a separate permit from the Ministry of Industry and Trade of the Russian Federation.
2. Compliance with international law:
International agreements, such as the UN Arms Trade Convention and other international documents, impose obligations on Russian companies to control the use of exported products.
3. Information support for recipient Countries:
Suppliers are required to inform the receiving country about the properties and purpose of the product, as well as ensure its proper labeling and packaging.
4. Continuous monitoring of end users:
Russian companies should regularly request information about the end user and the purpose of using the product.
Documents required to obtain an export permit
When applying for a license, the company is required to provide the following documentation:
- Application for a license;
- Description of the product and its properties;
- Technical documentation for the product;
- Information about the manufacturer and the manufacturer of the product;
- Operating instructions and user manuals;
- Commercial contracts and agreements with foreign partners;
- Expertise and approval of the competent authorities of the Russian Federation.
Specific documents for different types of goods:
- For electronics and software: FSB license for cryptographic information security tools.
- For chemical products: special permission from the Ministry of Health and Rospotrebnadzor.
- For aircraft and spacecraft construction: a separate license from Rostec State Corporation.
The export of dual-use goods is accompanied by a significant number of obligations and a complex procedure for obtaining permits, due to the specifics of the product itself and the need to comply with national and international laws.