Director

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Sarah Rice

Sarah leads clearBorder’s export control consultancy, bringing 25+ years of experience across customs and export control compliance. A trusted advisor on dual-use goods, ITAR, sanctions, and governance frameworks, she helps clients smoothly navigate the world’s most complex export corridors.

Known for turning regulatory complexity into commercial opportunity, Sarah works across sectors including defence, photonics, quantum, space, and more. She’s advised governments on national security, shaped UK–US compliance programmes, and built cross-border trade frameworks in the Middle East and North America.

Outside work, she’s a keen gardener (when the sun is shining!), and when it’s cold, you’ll find her gaming on the PC – usually in Azeroth.

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Export Controls

How to Classify Your Product’s export control entry in the UK. A Step-by-Step Guide

Exporting products from the UK involves more than just shipping logistics; it demands careful attention to regulatory compliance.    For many traders, one of the most important aspects of international operations is understanding and applying the right export control entry (or classification number). This alphanumeric code is crucial for determining whether your product falls under UK strategic export control regulations, and therefore requires a licence before shipping.   But… how do you know which classification applies to your product? And what happens if you get it wrong? Misclassifying your product can lead to:    Delays Hefty fines Criminal penalties   Today, we’ll break down the steps to correctly classify your product’s control entry number in the UK, examine its importance for compliance with both UK and international regulations, and offer practical tips for businesses navigating these requirements.   Whether you’re a seasoned exporter or just entering the global marketplace, the clearBorder team is here to help you trade seamlessly across borders. Book a FREE consultation today →   Related Reading What we talk about when we talk about ITAR compliance  Expanded Horizons: Trading With a SPIRE Export Licence   What Is a control entry number?    Export control entries, or classification numbers, are used to describe items that are controlled under the UK export control framework.    Unlike a Harmonized System (HS) code, which is primarily used for tariff classification, the control entry focuses on the specific nature of the product, including its technical specifications, potential military or dual-use applications, and how it may be controlled under national security, encryption, or technology transfer laws.    In the UK, the entries are part of the broader UK Strategic Export Control Lists, which align with international agreements and UK export regulations.   A control entry, described on this list helps determine whether an export licence is required for your product. It indicates the level of controls and identifies whether the item falls under UK restrictions or international agreements, like the Wassenaar Arrangement, which governs export controls for conventional arms and dual-use goods.   Get in touch now for independent export control compliance services →   Why It Exists   The control entry system exists to safeguard national security, protect human rights, and support international treaties that regulate the export of sensitive technologies and products.    Its primary purpose is to prevent certain technologies or goods from being exported to countries, individuals, or entities that could misuse them for military or prohibited purposes. By assigning a classification to a product, authorities can determine if an export licence is required, ensuring that goods leaving the UK meet all necessary security, trade, and diplomatic conditions.   This system also helps countries coordinate global export policies, ensuring that sensitive technologies are regulated consistently, thus avoiding the risk of one nation undermining international efforts to control the spread of strategic goods.   An Example Use Case   Imagine UK-based electronics manufacturer, TechNova Ltd, that produces advanced cryptographic communication equipment.    Before exporting to a client in another country, TechNova would need to classify its product’s control entry.  After reviewing the product’s specifications – especially its encryption capabilities – they determine that it falls under a specific entry related to encryption technology. With this classification, TechNova consults the UK Export Control Joint Unit (ECJU) and realises that the product is subject to strict export controls due to its potential for military use.  Therefore, they apply for an export licence and receive approval before shipping the equipment. This ensures compliance with UK law while securing TechNova’s international trade operation.    How to Classify Your Product’s ECCN Number: 8 Steps   Classifying your product’s export control entry in the UK is a crucial step in ensuring compliance with export control regulations. Failure to classify your product correctly can lead to delays, fines, and even prosecution.    Below, we’ve compiled a step-by-step guide to help you navigate this essential process.   Step 1: Understand the Need for Classification   Before diving into the classification process, it’s vital to understand why it’s necessary.    The control entries identify products that are subject to specific export controls based on their technical characteristics, potential military applications, and use in dual-use (civilian and military) scenarios.    These controls are in place to protect national security and to comply with international treaties. If your product falls under export control regulations, you may need an export licence from the UK Export Control Joint Unit (ECJU).   Step 2: Review the UK Strategic Export Control Lists   The first place to start is the UK Strategic Export Control Lists. This is a comprehensive list that covers all items controlled for export. The list includes:   Military goods Dual-use items Goods under WMD (Weapons of Mass Destruction) control Products subject to sanctions or embargoes   You can find the most up-to-date version of the control lists on the UK government’s Strategic Export Control Lists page.    Carefully examine these lists and compare your product’s technical specifications with the items described. If your product matches any of the listed items, it will require a licence to export from the UK.   Step 3: Identify Key Technical Specifications of Your Product   To classify your product correctly, you’ll need a detailed understanding of its technical specifications. This could include:   Functionality: What is the main purpose of the product? Performance: What are the operational parameters, such as speed, capacity, and precision? Materials and components: What materials and components are used, and do any of them have dual-use or military applications? End-use: How can the product be used, and by whom (e.g., military, civilian, or research institutions)?   Step 4: Consult the UK Control Lists Database   The UK government maintains an online Control List Classification Search Tool that allows you to search for control entries based on your product’s features. Here’s how you can use it:   Access the search tool on the UK Department for International Trade (DiT) website. Enter relevant keywords: Use terms specific to your product, such as its material or function. Browse the entries that appear as results. Each is linked to specific export control criteria, so check the description closely. Match your product’s specs: Compare the technical specifications of your product to the entries that appear to see if it fits under one.   Step 5: Determine If Your Product Is Military or Non-Military   The UK control lists are divided into Military and Dual-Use sections. If your product is specifically designed for military purposes, it will likely fall under the Military Goods section. These include items like:   Weapons, ammunition, and military vehicles Equipment and software designed for military use Technology specifically related to the development of military products   These goods are subject to tighter restrictions, and you’ll need to consult the entries enumerated with an ‘MLxx’ control entry.   If your product is for commercial or civilian use but could have military applications (e.g., drones, encryption software, etc.), then you may need to check the Dual-Use Goods section instead.   Step 5: Check the Control Criteria for Dual-Use Goods   If your product could have both civilian and military applications, it may fall under the Dual-Use Goods category. Dual-use items are goods, software, or technologies that can be used for both civil and military purposes.    Dual-use controls impact tens of thousands of items. This includes goods, technology and software. Even commercial off-the-shelf items can sometimes require a licence for export.   Step 7: Review Your Findings with an Expert   Once you have identified a potential control entry for your product, it’s wise to consult a trade compliance expert or the UK Export Control Joint Unit (ECJU). Misclassification can lead to severe penalties, so getting a second opinion is highly recommended.   You can reach out to clearBorder for expert trade consultancy services to help guide you through the process and verify your classification.   Step 8: Apply for an Export License (If Required)   If your product is described by a control entry, you’ll need to apply for an export licence. The type of licence you need will depend on the product, the destination country, the end-user and the end-use.    The main types of export licences include:   Open General Export Licences (OGEL): These cover multiple shipments of specific products to specific countries. Standard Individual Export Licences (SIEL): For specific shipments to a specific recipient. Open General Export Licences (OGEL): These cover multiple shipments of specific products to specific countries.   You can apply for an export licence online through the UK’s SPIRE system, managed by the Export Control Joint Unit (ECJU).   Moving Forward   Once you’ve applied for and received your export licence, there are some best practices it’d be a good idea to carry out. This is to make sure your operation stays compliant in the long-term; think of it as good housekeeping.    Keep Your Records Updated   After classifying your product and obtaining the necessary licences, ensure that you maintain accurate records of your classification and licensing decisions.    Regulations may change, and having up-to-date records can make it easier to comply with any future changes.   Reassess Classification Regularly   As the UK’s export regulations change or as your product evolves, it’s essential to periodically reassess whether the classification still applies.    Regulatory updates, technological advances, or new use cases for your product may shift its classification; keeping in regular contact with the UK Export Control Joint Unit (ECJU) or using clearBorder trade consultancy services can help ensure compliance.   Getting a control entry number In the UK: Key Takes   Ultimately, a well-executed classification helps protect your business from penalties, delays, and potential legal action. Here’s a quick recap of the essential points:   Your product may be controlled if it has dual-use, military, or sensitive technological features. The Strategic Export Control Lists and online search tools are valuable resources for identifying the right classification. Misclassification can result in fines and penalties. Consulting with a trade compliance expert, like clearBorder, ensures accuracy and peace of mind. Depending on the destination and nature of your product, you may need to apply for an export licence through the UK Export Control Joint Unit (ECJU). By correctly classifying your product, your business gains a competitive edge in international trade, minimising delays and securing quicker market access.   For businesses seeking to simplify UK classification and compliance, clearBorder offers expert consultancy services. Contact us today to learn more about how we can help keep your trade operation compliant and efficient. 

How to Classify Your Product’s export control entry in the UK. A Step-by-Step Guide
Customs compliance

Pro-forma or commercial invoices for export shipping?

Export Shipping Invoices: Pro-Forma or Commercial? A pro forma invoice is a preliminary quote, bill, or offer prepared by an exporter or seller to provide the buyer with an idea of the expected cost of the goods or services. Pro forma invoices take into account costs for shipping, taxes, unit pricing, and any applicable discounts or special offers. This document is not legally binding. The key components of a typical pro forma invoice include: Description of goods or services: a detailed explanation of the provided goods or services, including the prices, specifications, and any other terms or conditions. Estimated costs: an estimate of the cost for each good or service that accounts for the price per unit, taxes, shipping costs, and any applicable discounts. Contact information: contact information, including names, addresses, phone numbers, and email addresses, for both the buyer and the seller. Validity period: the date until which the pro forma invoice is valid. This helps in managing price fluctuations and ensuring timely action. Terms and conditions: the invoice may additionally contain specific transaction terms and conditions, such as payment requirements, delivery deadlines, and any applicable warranties or guarantees. Additional notes or terms: any special terms or conditions of the sale that both parties need to be aware of, such as warranties, return policies, or specific requirements. Understanding Pro Forma Invoices Pro forma invoices are widely used in international trade when dealing with new or potential customers since they provide a thorough picture of the projected costs before the final agreement is reached. When a buyer and seller are still in the planning or negotiation stages of a deal, a pro forma invoice is frequently used to provide a general sense of the costs, allowing the buyer to assess whether they can afford the purchase and adapt their budget accordingly.  Exploring commercial invoices A commercial invoice is a formal and legally binding document used in international trade transactions.  In addition to serving as an official request for payment from the buyer to the seller, it offers a comprehensive summary of the goods or services being offered. As opposed to a pro forma invoice, a commercial invoice is issued after a sale has been agreed upon and is used to facilitate the delivery of goods or the rendering of services. It is a crucial document for accounting, import/export regulations, and customs clearance. The key components of a commercial invoice include: Description of goods or services: a detailed explanation of the provided goods or services, including the prices, specifications, and any other terms or conditions. Commodity code: states the product identification code used in the country of export to classify the goods or products being exported. Country of origin: this section refers to the original place the items were manufactured rather than the country of export. This section includes a list of any products that are manufactured or produced in multiple countries. Total value: use the selected Incoterm to calculate the value of the commodities. If the seller is responsible for paying the freight and insurance expenses, these two items must also be mentioned. If the buyer is to cover the freight company and all additional fees, the commercial invoice will need to specify the worth of the goods. Shipping information: This document contains information regarding the shipment’s method of delivery, carrier, tracking information, and any pertinent shipping documents, such as airway bills or bills of lading. When and Why to choose Commercial Invoices Once a transaction is complete, the buyer will receive the commercial invoice alongside the goods. A commercial invoice serves as a binding agreement and record of a transaction between the seller and the buyer. It lays out the conditions of the sale, such as the number and description of the items, the due date for payments, and other essential details.  Commercial invoices are required for customs clearance when goods are shipped internationally, and they are also necessary for accounting as they ensure accurate financial reporting and tax compliance. Pro-forma vs Commercial: Key Differences to Consider Timing: Pro forma invoices are issued before the provision of goods or services; whereas commercial invoices are provided to the buyer following delivery of the goods or services to provide an accurate record of what was purchased and from whom. Purpose: A proforma invoice typically serves two purposes: informing customers beforehand about the costs related to their purchases, and providing sellers with information regarding specifics on the item’s description, quantity, unit price, and terms of delivery,  so they can set up a letter of credit or other payment method, obtain any required import licences, and overcome any potential import restrictions. Contrarily, commercial invoices provide a formal record of sale, which is frequently needed by customs officials when shipping products overseas. Customs officials use commercial invoices to accurately calculate any tariffs or taxes owed on imported goods.  Legality: Proforma invoices are typically used for estimates but have no legal standing, whereas commercial invoices are binding records that provide proof of the goods and services that were acquired. In conclusion, a commercial invoice is a final, legally-binding document used for actual transactions and customs clearance, whereas a pro forma invoice is a preparatory document used for quoting and delivering information. Pro forma invoice Commercial invoice Nature/purpose A pro forma invoice is a sales invoice that is sent by the seller to the buyer before the shipment of the actual goods. It gives a thorough description of the products, their quantities, their costs, and other sale conditions. The final invoice given by the seller to the buyer after the products have been dispatched is known as a commercial invoice. It is a formal record of the sale transaction that includes all the information needed for payment and customs clearance. Legally binding Pro forma invoices are not binding legal documents. They are used to give the buyer information and to make it easier to negotiate and agree on the conditions of the transaction. The commercial invoice, which contains the terms of the sale, including the agreed-upon prices, payment conditions, and delivery information, is a binding legal document. Customs and import procedures Customs officials frequently request pro forma invoices to determine tariffs, taxes, and other charges before the arrival of the actual goods. They give customs officials an estimation of the shipment’s value. When the goods arrive in the destination country, customs authorities use commercial invoices to determine the applicable duties, taxes, and fees. They include precise details regarding the cost of the items and the conditions of the sale. Payment information Pro forma invoices may include payment information, such as the approved payment method and any required upfront payments. Commercial invoices offer comprehensive payment details such as the total amount owed, the payment deadline, and the accepted payment methods. Used in quotations or payment When submitting quotes to potential customers, pro forma invoices are frequently employed. They assist purchasers in comprehending the expenses related to a potential purchase. The buyer initiates payment to the seller using commercial invoices. They are used to document the transaction and are frequently needed for accounting and tax purposes. Legal obligation Pro forma invoices are not legally binding, therefore they do not obligate the buyer nor the seller to make a purchase or deliver the goods. The seller is obligated by law to provide the items as specified in the commercial invoice, and the buyer is obligated by the commercial invoice to pay. What to keep in mind when choosing the right export shipping invoices In conclusion, a commercial invoice is a final, legally-binding document used for actual transactions and customs clearance, whereas a pro forma invoice is a preparatory document used for quoting and delivering information. To avoid delays caused by improper paperwork requirements and to guarantee that everything goes smoothly when shipping items internationally, businesses must understand which documents are necessary. Before shipment, having these documents in your possession will guarantee that your goods arrive on time and that you are in compliance with international trade regulations. clearBorder clearBorder provides independent advice on international trade, border systems, policies and processes. We deliver: online modular training suitable for individuals, teams or whole businesses to cut the risks and costs of trade across borders independent consultancy to ensure compliance, adapt businesses’ supply chains and maximise efficiency expert insight into policy and technology shaping the future trade borders, to enable clients to maintain their competitive advantage We deploy our expertise and extensive partnerships across the freight forwarding, customs, policy-making and trading sectors to help our clients trade seamlessly across borders. Contact information If you require further guidance regarding commercial and/or pro forma invoices, please contact us here. 

Pro-forma or commercial invoices for export shipping?
Export Controls

Dual-Use Items: What Are They And Why Are They A Challenge?

Dual-use items are products, technologies, or materials with both civilian and military uses.  These are goods which can be utilised for legitimate commercial purposes, however, they also have the potential to be modified for use in military or terrorist operations. Many technologies and products created for non-military uses can have qualities or features that make them appropriate for use in the military, which gives rise to the concept of dual-use items. What are the uses of Dual-use items? Dual-use items can have a variety of applications due to their versatile nature. Here are some examples of how dual-use items can be utilised in different contexts: Medical and Healthcare Applications: Advanced Imaging Technologies: Technologies developed for medical imaging, such as high-resolution cameras and sensors, can also be used for surveillance and reconnaissance purposes. Biotechnology Tools: Biotechnology equipment used for research in genetics and molecular biology can also have applications in the production of biological weapons. Information and Communication Technology (ICT): Encryption Software: Encryption software designed for secure online transactions and data protection can also be used to secure military communications. Satellite Communication Systems: Satellite communication technology used for global internet access can also be employed for secure military communication. Aerospace and Defence: Composite Materials: Lightweight and strong composite materials used in civilian aircraft manufacturing can also enhance the performance of military aircraft and missile systems. Navigation Systems: GPS technology, originally developed for navigation and location services, is crucial for military navigation and targeting systems. Energy and Power Generation: Advanced Batteries: High-capacity batteries developed for consumer electronics can be adapted for military use in portable equipment and vehicles. Power Generation Systems: Efficient power generation and storage technologies can benefit both civilian energy needs and military operations. Chemical and Manufacturing Industries: Chemical Precursors: Certain chemicals used in various manufacturing processes can also be components of chemical weapons, raising concerns about their potential misuse. Precision Machinery: High-precision manufacturing equipment used for producing complex consumer goods can also be used for manufacturing military components. Transportation and Logistics: Unmanned Aerial Vehicles (Drones): Drones developed for photography, surveillance, and package delivery can also be adapted for reconnaissance and even combat purposes. Electronics and Sensors: Sensor Technologies: Sensor technologies used for environmental monitoring can also have applications in military surveillance and targeting. Radar Systems: Radar technology developed for weather forecasting and air traffic control is crucial for military surveillance and defence systems. Nuclear Technologies: Nuclear Reactors: Nuclear reactors used for power generation can also be adapted for military propulsion systems in submarines and aircraft carriers. Radiation Detection Instruments: Instruments used to detect radiation in various contexts can be important for monitoring nuclear materials and preventing illicit nuclear activities.   It’s important to note that while dual-use items have valuable civilian applications that contribute to technological advancement, their potential for misuse requires careful monitoring and regulation to ensure international security and prevent the proliferation of sensitive technologies. Types of Dual-use items These items can include a wide range of products and technologies, such as chemicals, electronics, software, machinery, and more. Examples of dual-use items might include: Advanced Materials: Certain materials with properties like high strength or heat resistance can be used in both consumer products (like aerospace components) and military applications (like missile casings). Computing and Software: Software and computing technologies designed for civilian use, such as encryption software, can also have applications in securing military communications. Biotechnology: Technologies used in medical research can sometimes be adapted for the production of biological weapons. Telecommunications Equipment: Components used in civilian communication networks can also be employed in military communication systems. Aerospace Technologies: Technologies developed for civilian aircraft can also contribute to the design and development of military aircraft. The dual-use nature of these items raises concerns about their potential misuse for purposes that threaten national security or violate international agreements. To monitor and restrict the trade of dual-use items and keep them out of the hands of entities or people who might misuse them, many nations have established regulations and export controls. These regulations aim to strike a balance between advancing technology and preventing the proliferation of dangerous technologies.   Export controls on dual-use items typically involve licences and permits that must be obtained before certain items can be traded or moved across borders. These controls help ensure that technologies and products that could have both peaceful and potentially harmful applications are used responsibly and do not contribute to global instability or security threats. Challenges for Regulators Regulating items with legitimate purposes Dual-use items have the potential to advance scientific and human growth as well as build economic relations. Simultaneously, they pose a potential threat to global security objectives and the spread of weapons of mass destruction (WMDs). Regulators must develop an appropriate level of control so as not to hinder technological and economic advancement while mitigating risk to national and global security Export control regimes must keep pace with rapid developments in technology. Quantum computing, drones and AI are just some examples of the novel technologies challenging regulators to balance commercial demand and risk to international stability Identifying and assessing items Another challenge for regulation of dual-use items is the difficulty in identifying items that are designed for proliferation. Specialist knowledge, information, or advice is often required to determine the use and capabilities of the item and apply appropriate legal and regulatory restrictions.  Context  Context is another important component. For example, shipping drones to a well-established photography business in a low-risk country has different potential implications and risks than shipping drones to an unknown person in a high-risk country. Regulators must analyse not only the product, but also it’s potential end-use in each other nation. Challenges for UK businesses Identifying and assessing items Dual-use items are generally only export controlled when the items satisfy strict performance requirements or technical capabilities.  Individuals may require technical expertise to correctly determine whether their goods are export controlled as ‘dual-use’ items. Additionally, some items can be described using general terms that do not clearly identify the item or its intended purpose. To enable individuals to identify dual-use items in spite of any vagueness or uncertainty, training is required.  Many dual-use items are sold commercially and ‘off-the-shelf’. This can mislead people into thinking the goods are not subject to export controls.  Licences may be required to share dual-use information orally or via electronic devices with a non-authorised person. A transfer of export controlled information can happen during a phone call, via email or even during an online or in person meeting.  Applying for authorisation Companies or individuals can use the governments online licencing system SPIRE to apply for an export licence as required. The application process can frustrating for business and it can take some time to receive approval. Compliance   Failure to adjust export practices to comply with the appropriate regulations and licences could result in sanctions for the individual or company; therefore, it is important to seek expert advice to avoid legal or financial repercussions.  Conclusion Dual-use items may be freely available yet subject to the intricate laws and regulations of both UK and international export control regimes. Companies must be aware of their dual-use items and the implications of their export activities. Failure to keep up with the fluidity of these products’ restrictions can lead to violations with the potential of financial, and legal penalties.  If you have any questions regarding dual-use items, it is important to seek professional advice. clearBorder’s team of expert consultants are ready to help you ensure correct classification of your items and compliance with the rules. About us clearBorder clearBorder provides independent advice on international trade, border systems, policies and processes. We deliver: online modular training suitable for individuals, teams or whole businesses to cut the risks and costs of trade across borders Independent consultancy to ensure compliance, adapt businesses’ supply chains and maximise efficiency expert insight into policy and technology shaping the future trade borders, to enable clients to maintain their competitive advantage We deploy our expertise and extensive partnerships across the freight forwarding, customs, policy-making and trading sectors to help our clients trade seamlessly across borders. Contact information If you require further guidance regarding dual-use items, please book a call with our team here. 

Dual-Use Items: What Are They And Why Are They A Challenge?

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