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United KingdomGOV.UK

System outage changes nothing for controlled exports and ten destinations

During HMRC business continuity, normal declarations continue for listed controlled goods including military items, and for any goods to ten listed states.

By Taxxa AI OyPublished 6 November 2026

Tax Financial Sector & Markets

Industry: Across industries

Exporters of controlled goods from Great Britain must keep following normal export declaration rules when HMRC invokes business continuity plans for system issues.GOV The continuity fallback does not relax controls for these movementsGOV: file as normal.

The goods in scope are art, antiques and cultural goods, controlled chemicals, controlled drugs, medicines and medical devices, ozone-depleting substances, rough diamonds, strategic military and dual-use items that require export authorisation, and waste shipments. Each keeps its normal declaration and licensing route during a systems outage.GOV The guidance singles out strategic military and dual-use items: an export licence is needed before exporting controlled military goods, software and technology, or items on the United Kingdom dual-use list, from the United Kingdom to another countryGOV. Those items are listed in Schedules 2 and 3 to the Export Control Order 2008, as amended.

A second, destination-based trigger applies regardless of what is shipped.GOV If HMRC apply business continuity plans due to system issues, normal export declaration rules also apply to goods of any type exported from Great Britain to Belarus, Iran, Libya, Myanmar, North Korea, Russia, Somalia, Syria, Venezuela and Zimbabwe.GOV A consignment of ordinary commercial goods to one of those destinations therefore stays under full declaration discipline during an outage in the same way as a controlled-goods movement elsewhere.GOV

For a Great Britain export while business continuity plans apply, the guidance gives a goods list and a destination list, and either one brings the normal rules into playGOV. Where the goods are listed above, follow normal export declaration rulesGOV; where the destination is one of the ten countries named above, the same normal rules apply to goods of any typeGOV. For military and dual-use items, that includes obtaining the export licence before export.GOV Treat either list match as bringing the normal rules into play.

Legal basis: Export Control Order 2008, Schedules 2 and 3.

During any HMRC systems outage, file normal export declarations for listed controlled goods and for any goods to the ten named destinations, with licences secured first.

Sources

Exporting controlled goods from Great Britain during HMRC system issues