Clear documentation for responsible trade

Establish the product and transaction

A useful assessment starts with an accurate description of what is being supplied. The drawing, material specification and intended function help establish which classifications and controls need review. A customs tariff code and an export-control classification answer different questions; one should not be assumed to replace the other.

Identify the contracting parties, delivery destination and intended end user. Where an intermediary is involved, clarify its role. The European Commission's dual-use guidance explains the EU framework. Whether a particular product or transaction requires authorisation needs a specific assessment under the applicable rules.

Request information for a defined purpose

The review may require the buyer's legal identity, part specification, destination, application and an end-use statement. A competent authority or exporter may require a particular form or additional evidence. We clarify the request rather than describing every purchase as subject to an identical certificate.

An end-use declaration should accurately describe the proposed transaction. An NDA can protect confidential commercial information, but does not remove any disclosure that applicable law or the licensing authority requires.

Apply contract requirements where they belong

Some EU measures require contractual restrictions on certain transactions involving specified goods. Article 12g of Regulation 833/2014 and article 8g of Regulation 765/2006 have separate scopes and exceptions. They should not be treated as a single universal clause for every industrial export.

The relevant goods lists, transaction and current legal text must be checked before concluding that a particular obligation applies. Where required, contractual remedies and reporting obligations need to be addressed alongside the restriction. A website statement does not perform that contractual work.

Keep approvals and delivery assumptions visible

The quotation should distinguish technical feasibility from any licence or documentary condition still outstanding. An indicative production schedule is not an authority's approval date. If information changes, such as destination, end user or material composition, the earlier assessment may need to be revisited.

For Chinese rare-earth export controls, our export-licence guide separates product composition from grade names and explains why a fixed approval lead time cannot be promised.

Maintain a clear record

Agree which party supplies each document, what it covers and which version supports the transaction. Keep part and drawing references consistent across the enquiry, quotation and shipment records. Questions that remain unresolved should be identified before an unconditional commitment is made.

This is an overview of our intended review approach, not a legal determination for a specific order. Transaction-specific questions may require the relevant authority or qualified legal adviser. Our role as a trader does not replace their decisions.

Documentation questions