What is a dual-use item?

An item that can be used for civil as well as military purposes. Regulation (EU) 2021/821 lists these items in its Annex I. Whether a parachute or a technical textile falls under it is decided by the technical description of the list entry, not by the industry of the buyer.

Who issues an export license in Germany?

The Federal Office for Economic Affairs and Export Control. It issues individual licenses for a defined recipient and transaction, global licenses for recurring business, and administers the general authorisations, which can be used without an individual application but require registration, record keeping and reporting.

Why does the procedure ask about the end user?

Because alongside the control list the use decides whether a license is required. The regulation contains catch-all provisions under which an unlisted item also becomes subject to licensing once a critical use is known. End-user statements and re-export reservations record this information.

Does a granted license also cover onward delivery?

No. A license relates to the transaction it describes, meaning the item, the recipient, the country of destination and the end use. A re-export out of Europe into a further country is a transaction of its own with a review of its own, even where the same goods arrived under license.

Is technical documentation covered by export control as well?

Yes. Export control covers goods, software and technology, and technology includes drawings, specifications, test reports, manufacturing processes and training. A design document transmitted across a border can carry the same licensing requirement as the part that it describes, regardless of the route the transmission takes.

Export control · Overview

Export control and end use

Whether a recovery or protection system may be delivered is not settled by the purchase contract. It is settled by the control list, the end use and the license of the exporting state.

What export control covers

Export control does not stop at finished systems. It covers goods, software and technology — and technology includes technical documentation, design data and manufacturing know-how. A drawing sent across a border as an attachment can carry the same licensing requirement as the part it describes.

What matters is the classification of the individual item, not its name in a catalog. Depending on the design, textile recovery and protection systems can fall under entries of the dual-use list as well as entries of the military list.

Goods: parts, assemblies, complete systems, test samples.
Software: design, control and test software.
Technology: drawings, specifications, test reports, manufacturing processes, training.
Transactions: export, transfer within the Union for listed military items, re-export, technical assistance.

The control lists

In the European Union, Regulation (EU) 2021/821 brings the control of dual-use items together. Its Annex I holds the dual-use list, arranged in categories from materials and materials processing to aerospace. Annex II governs the Union general export authorisations.

Military items sit apart from this. In Germany they are held in the export list, Annex AL to the Foreign Trade and Payments Ordinance: Part I Section A covers weapons, ammunition and armaments, Section B nationally listed items. The procedures themselves follow the Foreign Trade and Payments Act and its ordinance.

One and the same fabric can be unlisted in a civil application and listed in a military design. Classification follows the technical description of the list entry, not the industry of the buyer.

End use, end destination and the catch-all provisions

Beside the list stands the use. Regulation (EU) 2021/821 contains catch-all provisions: an unlisted item also becomes subject to licensing where the exporter is aware, or has been informed by the authority, that it is intended for a critical use.

Every licensing procedure therefore asks about the recipient and the end destination. End-user statements, re-export reservations and a description of the project the system will operate in are the usual instruments.

Who operates the system in the end and who carries responsibility for it.
What it is used for and in which project.
Where it is operated and where it is stored.
Whether a transfer to third parties is foreseen.

Licenses and the competent authority

In Germany the competent authority is the Federal Office for Economic Affairs and Export Control. It issues individual licenses for a defined recipient and transaction and global licenses for recurring business. Alongside these stand general authorisations, usable without an individual application but requiring registration, record keeping and reporting.

How long a procedure takes depends on the item, the country of destination, the recipient and the completeness of the documents. A license that has been granted relates to the transaction it describes; it covers no divergent delivery and no other end user.

How a delivery into and out of Europe runs

A delivery from the country of manufacture is first subject to the export law of that state. Once the goods have arrived in the European Union, every further movement follows Union law together with the national law of the member state the goods are exported from.

A re-export out of Europe is a transaction of its own with a review of its own — even where the same goods were previously imported under license. For project planning this means that classification, end-use information and licensing stand at the beginning of the schedule, not at its end.

What these pages do not say

This page sets out the general legal position. It is neither legal advice nor a classification ruling for a particular item; only the statement of the competent authority is binding.

APCO Defense Europe supports projects in Europe, places enquiries in their technical context, establishes contact with the manufacturer and obtains documentation. Classification, licensing and testing rest with the bodies responsible for them and with the manufacturer.

Source: apcodefense.com (APCO Aviation), as of 25 September 2026.