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Following Russia’s invasion of Ukraine on 24 February 2022 the Prime Minister, Boris Johnson, announced plans to ban the export of all dual-use items to Russia. 

Dual-use items are goods which can be used for both a military and civil purpose (such as electronics, lasers or chemicals). New legislation came into force on 1 March 2022.

Russia is already subject to an arms embargo, which was imposed by the EU following its annexation of Crimea in 2014 and which has been continued by the UK following its exit from the EU.  

This paper discusses UK restrictions on arms and dual-use exports imposed on Russia since 2014. The relevant legislation are:

Information on the broader sanctions’ regime can be found in Commons Library paper Sanctions against Russia.

What are dual-use items?

Dual use items include physical goods, software and technology. The list of military and dual-use goods which are controlled, and therefore require a licence for export, are collated in the Consolidated list of strategic military and dual-use items that require export authorisation (frequently referred to as the Consolidated List).

Arms embargo applied in 2014

After Russia’s annexation of Crimea in 2014 and its destabilising efforts in eastern Ukraine, the EU imposed a sanctions regime on Russia that included an arms embargo, as Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014. 

The embargo prohibits the supply to Russia by nationals of EU states or from the territories of EU states of:

  • arms and military-related services
  • the sale, supply, transfer or export of dual-use items for military use or to military end-users (exceptions include technology for aeronautics and for the space industry)

The embargo has been renewed and maintained by the EU ever since.

The Russia (Sanctions) (EU Exit) Regulations 2019 ensured sanctions relating to Russia continued to operate effectively after the UK left the EU. It came into force on 31 December 2020. The relevant sections can be found in Part 5, chapters 2 and 3 of the legislation.

Countries and destinations subject to arms embargoes are listed in Schedule 4 of the Export Control Order 2008 (SI 2008/3231). Amendments may be made via an Export Control Order.

New measures introduced in 2022: A ban on all dual-use items 

On 24 February 2022 the Prime Minister announced plans to ban the export of all dual-use items to Russia:

We will bring foward new legislation to ban the export of all dual-use items to Russia, including a range of high-end and critical technological equipment and components in sectors including electronics, telecommunications and aerospace. Legislation to implement this will be laid early next week. These trade sanctions will constrain Russia’s military-industrial and technological capabilities for years to come.

New regulations

The new legislation was made and laid on 28 February 2022 and came into force on 1 March 2022. MPs approved the measure on 1 March 2022.

The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2022, amends Part 5 (Trade) of the 2019 Regulations and is made under section 55(3) of the Sanctions Act. The accompanying explanatory notes explain the main changes:

  • The regulations replaces the existing prohibitions relating to dual-use items with new prohibitions on the export, supply and delivery, making available and transfer of dual-use items to, or for use in, Russia, irrespective of end-user.
  • The regulations prohibits the export, supply and delivery, making available and transfer of critical industry items to, or for use in, Russia.
  • The regulations also provide for exceptions from these measures, licensing and enforcement, and the creation of criminal offences.

Suspending existing licences

The Export Control Joint Unit (ECJU) manages the UK’s export controls and licensing for military and dual-use items.

On 28 February the ECJU announced it would suspend all existing export licences for dual-use items to Russia and the approval of any new export licences.

The Government has also removed Russia as a permitted destination from nine open general export control licences (OGELs). OGELs are pre-published licences that allow registered companies to export items to specified countries without applying for an individual licence.

Sanctioning Russian defence companies

In addition, on 24 February 2022 Liz Truss, the Foreign Secretary, announced sanctions on five major Russian defence companies.

Further reading

The Ukraine crisis page collates briefings from the Commons and Lords Libraries on the situation in Ukraine. This includes briefings on sanctions and UK trade with Russia:

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