Editorial
“Our customer is in Germany. They will be the ones to export it.”
When that answer arrives, our first question is generally: what do we know about what happens next?
The customer may be an end user, a distributor or an integrator. The delivery address tells us about one stage of the product’s journey. It does not always tell us where it will be used, by whom, or for what.
That does not mean the French supplier must take on all of its customer’s obligations. But before concluding that the transaction raises no particular question, we try to understand each party’s role and the information already available.
In this issue, we start from a common situation: a sale to a partner established in the European Union, for a project whose final destination is elsewhere.
The case
Consider a French SME that makes a measurement module for industrial equipment. A German integrator orders several units to build into a system.
Delivery is planned to its factory in Germany. But during the discussions, the customer explains that the complete system will then be delivered to a user outside the European Union.
“We deliver to Germany.”
“We will handle the export of the system.”
Can the company conclude that the final destination is not its concern?
Not yet.
Five questions we ask first
Who is our customer in this transaction?
An integrator buys in order to build a product into something else. A distributor buys to resell. An end user buys to use it.
So we first establish the customer’s role, then identify the other known parties: physical recipient, any intermediary and the end user. These roles can be held by different companies.
Where is the product going after our delivery?
We distinguish the billing address, the place of delivery and the intended place of use. In our case, Germany is where the module is integrated. It is not the announced final destination of the system.
So we ask which country is involved, who will use the system and for what application. This information lets us pin down the checks to carry out on the parties, the destination and the end use.
If some answers are missing, we try to understand why, and whether they are needed to decide whether to deliver.
What does the classification allow us to conclude?
We go back to the status of the module actually delivered by the French SME. Its classification identifies the controls to examine for the transfer to Germany. Some dual-use items, notably those in Annex IV, require an authorisation even between Member States.
The Regulation also provides for controls on certain other intra-Union transfers when a subsequent export is known, subject to several cumulative conditions. So the mere announcement of a non-EU destination is not enough to conclude that an authorisation is required.
Finally, the module’s classification is useful information for the integrator’s analysis of the finished system. It does not replace that analysis.
Is the project consistent with the information received?
We compare the product’s characteristics, the companies’ activity and the announced use. We look at the relevant restrictions and sanctions.
A poorly explained technical need, contradictory destinations or a refusal to describe the project call for further questions. Missing information has to be understood, then handled according to how much it matters to the decision.
Who does what, and what information needs to flow?
Who will decide to ship the system outside the Union? Who will examine the authorisations needed? What information should the supplier pass to the integrator?
A clear split of tasks makes the work easier. Each party needs the elements required to analyse its own transaction.
The method
When a European customer plans to export the product, or the system that incorporates it, we try to understand what follows in order to determine what must be checked before our own delivery. Our reasoning can be summed up like this:
- Describe the product and its regulatory status
- Reconstruct the known stages of the transaction
- Identify the parties’ roles and the intended use
- Check the controls that apply to our delivery
- Share the relevant information with the customer
- Document the decision and the points still to be confirmed
Requests for information should remain proportionate to the product, the project and the risks identified.
The reflex
Before delivering, put the right questions into circulation and keep a record of the answers. A few simple actions make this approach concrete:
- Add three questions to your order preparation: will the customer use the product itself? If not, in which country will it be used and for what application? Record the end user’s identity once it is known.
- Keep the information in one file. A country mentioned by an engineer, a user named in an email or a destination stated in the specification must be accessible to the person who approves the delivery.
- Check that the answers agree. Compare the purchase order, the commercial exchanges and the technical information. If the destinations or uses differ, ask for the intended route to be clarified before going further.
- Give the customer the documented classification and the relevant control information. Specify the references and versions concerned so that they can use them in their own analysis.
- Provide a validation step for significant uncertainties. Name the person to consult when a destination remains unexplained, a user cannot be identified or an answer contradicts the information received. Record the decision and what justifies it.
- Ask to be told of changes before shipment. A new country, a different user or a change in the intended use should let you re-examine the transaction in time.
The right reflex: make these checks a routine step of order handling, with a named owner.
Takeaway
Your customer’s address tells you where you are selling. It does not always tell you where your product will be used.
Radar To watch · early December 2026
United Kingdom: announced changes to the control lists and general authorisations
On 23 October 2026, the Export Control Joint Unit (ECJU) announced a proposal to amend the UK export control framework. Subject to ministerial and parliamentary approval, the texts should be laid before Parliament in November, with entry into force expected in early December.
Two changes are worth watching:
- The military and dual-use lists would be updated, notably for semiconductor manufacturing equipment, advanced computing technologies and certain specialised materials.
- General authorisation GEA001 would be revoked in Great Britain, where it has been replaced by the Dual-Use Open General Export Licence. Exporters already registered could keep using it until 1 April 2027. The change would not apply to Northern Ireland.
Who is affected? Companies exporting from the United Kingdom, and their European partners whose supplies depend on those exports.
What to do? Identify the products and flows that may be affected, check the authorisations used by your UK entities or suppliers and follow the publication of the final texts. The announced timetable remains provisional.
Status as of 30 October 2026. Source: ECJU, Notice to exporters 2026/24, 23 October 2026.
Advisory only — not legal advice.