Guidance

Strategic export controls: licensing statistics quality and methodology information

Updated 12 December 2024

This guidance is for all users but we expect the main users to be expert analysts and technical users, such as statisticians and analysts who do trade policy analysis.

It explains how the Export Control Joint Unit (ECJU):

• sources data for the strategic export controls licensing statistics

• maintains data quality

• deals with methodology amendments

Data sources

We source data from our administrative records.  ECJU is in the process of introducing a new digital system for export licensing, known as LITE, which will replace its legacy system, SPIRE. Therefore, at present, 2 administrative sources, SPIRE and LITE, are used to produce the strategic export controls statistics. With the introduction of LITE in 2021, this release has included data from both SPIRE and LITE from the 2021 Q3 publication onwards. Prior to the 2021 Q3 publication, this release provided data solely from SPIRE.

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. For further details, please see the Data quality section below and the statement of administrative sources guidance.

Export licences

ECJU administers the UK’s system of export controls and licensing for military and dual-use items. ECJU is part of the Department for Business and Trade.

Licence applications are submitted to and processed by the ECJU through SPIRE and LITE. ECJU issues licences for controlling the export of strategic goods.

Whether or not an export licence is required is determined by 4 factors, the:

• nature of the goods due to be exported

• destination concerned

• ultimate end use of the goods

• licensability of trade activities of the goods due to be exported

Licences are either standard or open.

Standard licences tend to name a specific quantity of specific goods for export to a specific destination. Generally, open licences have fewer restrictions than standard licences. They may include a wider range of goods or destinations. Exports under open licences generally do not place limits on the quantity of goods.

Licences are also either individual or general.

General licences are pre-published. All eligible exporters or traders can use them if they adhere to the terms and conditions of the specific licence. We issue individual licences following a successful application. We allow only those named on the application to export or trade certain goods.

See guidance on types of export licences.

Collection methodology

We use data collected through SPIRE and LITE to produce the strategic export controls licensing statistics. Data is organised primarily by each licensing decision. We exclude No Licence Required (NLR) decisions made on licence applications from all reports except for when we calculate the time taken to process licences.

Licensing process

Applications for the different individual licences are broadly processed in a similar way. The application arrives with the licensing reception team. It then passes through several other teams. Each team has a specific audit or checking function.

For example, our Technical Assessment Unit (TAU) reviews the goods by:

• assessing the technical aspects

• assigning control entries

This helps inform the outcome of the licensing request (such as issue or refuse).

The licensing procedure requires many checks by different ECJU teams and advisory departments. Details are re-checked before final publication of data based upon the licensing information. Information about some licences is also shared with His Majesty’s Revenue and Customs (HMRC). HMRC make customs declarations via the Customs Handling of Import and Export Freight (CHIEF) system.

ECJU licensing support

We provide a range of help to ensure that users complete licence applications correctly. This increases the quality of the licensing statistics produced from SPIRE and LITE.

Support includes:

• export control training, including induction for beginners

• a helpline for general queries about strategic export licensing during business hours

• advice and support during audits

Processing statistics

Initial processing time is the basis for the calculation of the processing statistics. That is, the time elapsed from when the application is first received to when it closes.

Closed cases

Closed cases include those where:

• a licence is issued

• the application is refused or rejected

• the application is stopped or withdrawn

• there was a No Licence Required (NLR) decision made on the application

Revocations apply to existing licences only, so are not counted.

We exclude any time spent:

• waiting for documents from applicants

• waiting for applicants to respond to a request for further information

During this time the application is said to be ‘Returned for Information’ (RFI).

Initial processing time

We count initial processing time in working days. This calculates the number of working days elapsed between when the application was first received and when it was closed, minus the number of working days it was RFI. Median days are always rounded down for reporting purposes.

A working day excludes Saturdays, Sundays and public holidays. We count a business day as a full day if the application was open at any time during the day. That is, the time part of the day is ignored. We count a business day as a full RFI day if the application was RFI at any time during the day.

Example of methodology

Initial processing time = 2 working days when this scenario applies:

1. ECJU receives an application at 10am on Monday

2. ECJU issues a licence at 5pm the next day

Initial processing time = 1 working day when this scenario applies:

1. ECJU receives an application at 10am on Monday

2. ECJU returns it for information on the same day

3. The applicant returns the requested information on the same day at 4pm

4. ECJU issues a licence at 5pm the next day

In this scenario, the application was open for 2 working days and RFI for 1 working day. Hence the initial processing time is: 2 days open – 1 RFI day = 1 working day.

For SIELs, there are government targets to process 70% of applications within 20 working days and 99% within 60 working days. For open individual export licences (OIELs), we aim to process 60% of applications within 60 working days.

With the introduction of LITE in 2021, this release has included data from both SPIRE and LITE from the 2021 Q3 publication onwards. Prior to the 2021 Q3 publication, this release provided data solely from SPIRE. Whilst the 2023 Q1 publication onwards has still included data from both SPIRE and LITE, there are some limitations in how we have published the LITE data for these reporting periods – any SIEL figures that provide the data broken down by initial processing times do not include SIELs processed in LITE for the 2023 Q1reporting periods onwards. These limitations result from differences in how SPIRE and LITE currently calculate initial processing times, which up until the end of the 2022 Q4 reporting period, we manually fixed for SIELs processed in LITE ahead of publication to ensure they were presented on a consistent basis (as per the methodology outlined above).

These limitations are caveated alongside the impacted figures in the 2023 Q1 publication onwards. Comparing figures from the 2023 Q1reporting periods onwards with previous reporting periods should be done so with care due to these limitations. For further details, including a high-level overview of data on export licencing decisions made in LITE for each quarter, please see the statement of administrative sources guidance

Licensing statistics

The data includes licences that were issued, refused, rejected or revoked in the period in which the outcome was decided. When calculating processing times, the data also includes applications which were not fully processed, for example where an application was stopped, withdrawn or No Licence Required (NLR).

The data does not cover certain changes to an existing licence - such as re-opening an application to make changes such as extensions to licences, removing good/s (although this is not done for OIELs), removing country/countries, or amending applicant errors.

If goods or destinations are added to an application and subsequently end up on a licence, they will be reported as a new issue for that period and the existing items on the licence will not be re-reported. The same applies for items removed from an application on an amendment, except in this case it will be reported as revoked.

In a small number of cases there may be a subsequent change of status during the same or a later period. There are 2 main reasons for such changes: a licence issued during the period may have been issued then subsequently revoked, for example because of the imposition of trade sanctions or an arms embargo; or a decision to refuse a licence, made during the original period, might be overturned because the applicant later appealed successfully and the licence was issued. These cases are flagged as Rv and A respectively in the historic PDF country pivot reports for 2021 Q2 and before, or in the columns “Some or all subsequently revoked” and “Some or all issued on appeal” in the ODS country pivot reports from 2021 Q3.

The data on refused SIEL applications does not include those refused during this period following an appeal against an earlier refusal. The SIELs data also does not cover goods that were removed from an application before a licence was issued, applications that were withdrawn or stopped before a decision was reached, or applications where it was determined that no licence was required or that the goods could be exported to the destination concerned under an OGEL.

Classifications and definitions

Strategic goods include military goods and a wide range of ‘dual-use’ goods (civilian goods with a military purpose). We assess goods against the UK Strategic Export Control Lists. This is a list of goods that need export authorisation.

It is possible for a licence to be for both military and dual-use goods.

Case summaries

Case summaries are text descriptions which:

• classify goods on licences

• are standardised, to facilitate comparison and analysis

• explain what the goods are without giving away commercially sensitive details (such as design or intellectual property)

Case summaries aim to achieve a balance. They provide enough detail so that users understand the nature of the goods, but not the exact details.

The use of prefixes gives extra detail. For example, by describing a replacement part for a sporting shotgun as ‘components for sporting shotguns’. This is instead of just ‘sporting shotgun’.

The TAU assigns case summaries. It bases them on the design intent. Classification is largely determined by the control entry given to the goods. Case summaries are less well defined than control entries. Thus classification of goods into case summaries is more subjective. This is although TAU selects them from an internally agreed list.

The list of case summaries is generally reissued following major legislative changes. Between updates there can be:

• minor amendments to existing descriptors

• addition of a case summary description for a control entry previously without a descriptor

Case summaries are provided for all licences issued in the period or where the coverage of an existing licence was amended during the period by the inclusion or reinstatement of this destination or by the addition of goods. Case summaries are provided for licences fully revoked, refused in full or whose coverage was amended during the period by the removal of items and/or destinations.

The destination coverage of an OIEL may be amended for a variety of reasons, but mainly in the light of recommendations received from advisory government departments. Sometimes amendments follow the imposition of an arms embargo, but they may also reflect general concerns about the destination or a relevant change in circumstances there.

A decision to exclude a particular country from the coverage of an OIEL does not mean that country is permanently excluded. Where the concerns that led to the original decision are no longer relevant, it might be decided to reinstate that destination.

The OIELs data does not cover applications from which specific goods or destinations were removed before an OIEL was issued or applications withdrawn before a decision was reached. It also does not cover applications where it was determined that no licence was required or where the items could be exported to the destination concerned under an OGEL.

The information does not cover OIELs whose period of validity was extended temporarily during the period pending a decision on an application for a new OIEL. Such cases amount to a temporary extension of an OIEL granted in an earlier period. The decision on the new application will be covered in this or a future report, depending on the timing of the decision. As OIELs cover multiple shipments of specified goods to specified destinations or specified recipients, exporters holding OIELs are not asked to provide details of the value of goods they propose to ship under an OIEL and it is therefore not possible to provide information on the total value of OIELs issued

Control entries

Control entries are codes. Each good on the list of goods that need export authorisation (‘UK control lists’) has a code assigned. For example, all control entries beginning ‘ML’ (such as ML1, ML8) are control entries for military goods.

 The TAU verifies control entries. Control entry descriptions are well defined in the UK control lists.

The control entries reported are less detailed than those listed in the consolidated list of goods that require export authorisation. For example, we report ML1 but there are more specific codes such as ML1a, ML1b, ML1c and ML1d. See a summary of amendments to the UK control lists.

Rating

We assign control entries to goods in a process called ‘Rating’.

In some cases ECJU can make goods subject to control even if they do not appear on the UK control lists.

We give the rating ‘end-use’ to goods where there is potential use in weapons of mass destruction (WMD). This is when the exporter has been told, knows or suspects the goods are, or may be, intended for ‘WMD Purposes’.

We give the rating ‘MEND’ to goods where there is potential for use as parts of military goods. This is when the exporter has been told, knows or suspects the goods are, or may be, intended for use as:

• components in, or production or test equipment for, military equipment in an embargoed destination

• parts of military goods illegally obtained from the UK, irrespective of destination

Both of these ‘end-use’ ratings are also sometimes referred to as ‘catch all’ ratings.

One or more control entries can be used to rate more than one good on a licence.

The description of a single control entry can comprise one or more case summaries.

We rate goods as one of the following:

• military (with a control entry assigned from the UK Military List within the UK control lists)

• non-military

Non-military goods:

• appear on other lists within the UK control lists, such as the UK dual-use list

• include goods refused to destinations with sanctions, such as trade sanctions or an arms embargo

Licences for goods affected by sanctions are not approved. The goods do not get rated against the UK control lists. They are instead rated with a sanction code, such as ‘RUS’ for Russia and ‘IRN’ for Iran.

Torture goods category

We class torture goods as non-military goods. They appear separately to the statistics on licences for non-military goods. We do not include goods covered by the Torture Regulation in the count of non-military goods for other SIEL sub-types.

The Torture Regulation applies to trade in certain equipment and products. These are items which could be used for:

• capital punishment

• torture

• other cruel, inhuman or degrading treatment or punishment

As noted, goods can also be rated even if they don’t appear on the UK control lists. Read the guidance about export controls on goods that can be used for torture or capital punishment.

Licence refusals and rejections

We assess all licence applications against the Strategic Export Licensing Criteria. This is done on a case-by-case basis. We will refuse a licence application if it fails one or more of the 8 criteria.

Depending on the nature of the goods, there may be consideration of other policy aspects. For example, we will assess items against the UK’s incorporation factors policy. This is if the exported goods are for incorporation into another system, equipment or plant.

Licence applications can be:

• rejected (for open individual licences)

• refused (for standard individual licences)

If we reject an application for an OIEL the applicant could apply for a SIEL. The same applies to an OITCL. A rejected applicant could apply for a standard individual trade control licence (SITCL). Any licensing decision for a SIEL or SITCL would take account of the factors that led to the original decision.

If we refuse an application for a SIEL there are no further licensing options for the exporter or trader to pursue.

Licences can also be revoked at any time after being issued.

Footnotes

We add case and goods footnotes to certain cases. These explain the end-use and/or end-user. These are available in the quarterly country pivot report.

The Foreign, Commonwealth and Development Office (FCDO) collaborate with ECJU to draft country footnotes. They are available in the quarterly data tables. Country footnotes appear against destinations. They aim to help the user understand why certain goods may have been approved in the period.

Data quality

The European Statistical System sets out 6 measurements of quality against which we assess data.

Relevance

Relevance is the degree to which the statistical product meets user needs. This is for both coverage and content.

The data is from 1 January 2008. It includes all licence applications where ECJU has made a decision to:

• issue

• refuse or reject

• revoke

It covers applications made for all controlled goods. This is for exports from the UK, or by applicants brokering exports in the UK.

Government departments using the data to inform their operations are:

• Foreign, Commonwealth & Development Office (FCDO)

• Ministry of Defence (MOD)

Other uses of the data in government include:

• in the strategic export controls annual report on UK’s export control policy and practice

• informing the work of the Business and Trade Committee (BTC)

Other users track strategic exports through this data. They are non-governmental organisations (NGOs) and academic and research institutions. They include:

• the Campaign Against the Arms Trade (CAAT)

• Amnesty International

• the Export Control Advisory Committee (ECAC)

• the Export Group for Aerospace and Defence (EGAD)

The Small Arms Trade Transparency Barometer scores statistics on transparency using 7 categories.

They are:

• timeliness

• access and consistency

• clarity

• comprehensiveness

• deliveries

• licences granted

• licences refused

The Transparency Barometer 2022 ranks the UK second using its assessment of transparency, up from fifth in 2021. ECJU’s statistics offer more transparency than similar statistics produced by most other countries.

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

Accuracy and completeness

This includes the closeness between an estimated or stated result and the unknown true value.

The licences covered by the data are a census of licences ECJU has:

• issued

• refused or rejected

• revoked

Numbers of cases are based on the date the licence decision was made (when the case was closed). Depending on the age of the licences, some may still be live (extant). Others may have expired or been surrendered by the applicant.

Checks are in place to identify and remove duplication of cases to:

• ensure that returns cover all reporting areas

• verify consistency within and between related data tables

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

Coherence

This is the degree to which data which are derived from different sources or methods, but which refer to the same phenomenon, are similar.

The status of a licence can change over time. For example, the revoking of an issued licence.

Historical country pivot reports reflect any amendments made to licences. The full data series back to 2008 Q1 are complete (as per the snapshot of data).

From the 2023 Q1 publication onwards, there have been some limitations in the LITE data we have published due to limitations in relation to the ability to extract comprehensive and accurate licensing data from LITE, with impacted statistics having been caveated in each impacted publication appropriately:

• 2023 Q1 to 2023 Q4:  These statistics were sourced from both SPIRE and LITE. However, there were some limitations in how the LITE data was published – any SIEL figures that provided the data broken down by initial processing times did not include SIELs processed in LITE for these reporting period.

• 2024 Q1 onwards: These statistics were sourced from both SPIRE and LITE. However, in addition to the limitations introduced from the 2023 Q1 publication onwards, there are further limitations in how the LITE data is published – only SIEL figures that are only broken down by licence outcome and/or licence sub-type include SIELs processed in LITE for these reporting periods.

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

Timeliness and punctuality

Timeliness refers to the elapsed time between publication and the period to which the data refer. Punctuality refers to the time lag between the actual and planned dates of publication.

Historically, we have published data from each quarter roughly 3 and half months from the end of the reporting period. For example, we published data relating to Q1 of 2015 (1 January 2015 to 31 March 2015) on 21 July 2015. Under normal circumstances, a snapshot of licensing data from SPIRE (and LITE from 2021 Q3) is generally taken 3 to 4 weeks before publication, which  allows us time to compile the publication outputs, such as the data tables and statistical commentary. This is the earliest publication date which ensures we can quality check the data. It allows enough time to elapse so that we can share the data with confidence. Furthermore, releasing data sooner may affect market activity. For example, publishing licence details in real-time could allow competitors to track issued licences, which could give a sign of business activity.

From the 2021 Q3 publication onwards, there have been some delays in publishing these statistics due to the transition from SPIRE to LITE, and the additional burden this has placed in relation to the production of the statistics and quality checking the data. This has meant that we have published outside of our expected timetable of roughly 3 and half months from the end of the reporting period. For instance:

•  the 2023 Q2 release was published on 16 January 2024, roughly 6 and a half months from the end of the quarter (30 June 2023)

• the 2023 Q3 and 2023 Q4 releases were published together on 13 June 2024, roughly 5 and a half months from the end of the latter quarter (31 December 2023). The 2023 Q3 and 2023 Q4 releases were published simultaneously in order to minimise the impact of the ongoing delays. Please note that we have only published the ‘Strategic export controls: licensing statistics’ table for the 2023 Q3 release as everything else, including tables A-H and associated commentary, was subsequently updated and published as part of the 2023 Q4 release

• the 2024 Q1 and 2024 Q2 releases were published together on 12 December 2024, roughly 5 and a half months from the end of the latter quarter (30 June 2024). The 2024 Q1 and 2024 Q2 releases were published simultaneously in order to minimise the impact of the ongoing delays. Please note that we have only published the ‘Strategic export controls: licensing statistics’ table for the 2024 Q1 release as everything else, including tables A-H and associated commentary, was subsequently updated and published as part of the 2024 Q2 release

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

To ensure transparency around expected dates of the publication, the GOV.UK research and statistics calendar provides details of the next publications release date.

Accessibility and clarity

Accessibility relates to the:

• ease with which users can access the data

• format in which the data are available

• availability of supporting information

The strategic control export licensing statistics:

• are available free of charge on GOV.UK

• meet accessibility requirements for publishing on GOV.UK or accessible versions are available on request

ECJU conducted a review of the statistics from January to July 2015. This assessed them against the Code of Practice for Statistics. Following this review, the statistics were determined to be compliant, besides one exception. The exception to code compliance is that on 4 June 2015 the UK Statistics Authority approved a request to be exempt from T3.7 of the Trustworthiness pillar of the Code of Practice for Statistics (that “The name and contact information of the lead statistician or analyst responsible for production should be included in the published statistics”).

Please see the UK Statistic Authority’s page for Code of Practice exemption requests for more information.

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

Comparability

This is the degree to which we can compare data over time and domain.

Changes over the years can affect the data. Examples include export control policy changes or operational changes to SPIRE and LITE. The data tables and commentary detail these. We manage operational changes to SPIRE and LITE through a formal change management process. We test thoroughly before applying changes to the live system.

Historically, a purpose-built digital licensing system called SPIRE has been used. However, ECJU is currently in the process of developing and rolling out a new digital licensing system, known as LITE, which will eventually replace SPIRE. During the transition period, ECJU are handling applications on both SPIRE and LITE. Therefore, these statistics have included data from LITE since 2021 Q3, the period in which the first licensing decision was made in LITE. This transition has impacted upon the timeliness and comprehensiveness of the publication.

From the 2023 Q1 publication onwards, there have been some limitations in the LITE data we have published due to limitations in relation to the ability to extract comprehensive and accurate licensing data from LITE, with impacted statistics having been caveated in each impacted publication appropriately:

• 2008 Q1 to 2021 Q2: Prior to the 2021 Q3 publication, licensing decisions were made solely in SPIRE. Consequently, these statistics were sourced solely from SPIRE and could be considered wholly comprehensive.

• 2021 Q3 to 2022 Q4: Following the period in which the first licensing decision was made in LITE (2021 Q3), these statistics were sourced from both SPIRE and LITE, meaning they could still be considered wholly comprehensive.

• 2023 Q1 to 2023 Q4:  These statistics were sourced from both SPIRE and LITE. However, there were some limitations in how the LITE data was published – any SIEL figures that provided the data broken down by initial processing times did not include SIELs processed in LITE for these reporting period.

• 2024 Q1 onwards: These statistics were sourced from both SPIRE and LITE. However, in addition to the limitations introduced from the 2023 Q1 publication onwards, there are further limitations in how the LITE data is published – only SIEL figures that are only broken down by licence outcome and/or licence sub-type include SIELs processed in LITE for these reporting periods.

Impacted statistics have been caveated in each impacted publication appropriately. For further details, please see the statement of administrative sources guidance and the quality and methodology information guidance.

From the 2024 Q1 publication until further notice, these statistics have been reclassified and published as Official Statistics in Development. Further details can be found in the statement of administrative sources guidance.

Background

ECJU handles the export of strategic goods and technology. ECJU is part of the Department for Business and Trade (DBT). It sets the regulatory framework for consideration of export licence applications.

The Secretary of State for Business and Trade and President of the Board of Trade takes the formal decision to:

• issue or refuse export licence applications

• suspend or revoke extant licences

Decisions are within applicable legislation and public policy.

The Strategic Export Controls Annual Report has more information on:

• recent strategic export control legislation

• recent policy implementation

Policy advice and technical assessment

FCDO and MOD act in a policy advisory capacity. They provide ECJU with advice and analysis on foreign, defence and international development. This informs ECJU’s consideration of licence applications against:

• the UK strategic export control lists

• other relevant policies

The National Cyber Security Centre (NCSC) is the UK government’s national technical authority for information security. It assesses goods involving sensitive communications or computer technology.

Enforcement

His Majesty’s Revenue and Customs (HMRC) has responsibility for:

• the enforcement of export and trade controls

• sanctions and embargoes

HMRC works with Border Force to detect breaches. It pursues prosecutions through the Central Fraud Group within the Crown Prosecution Service (CPS).

Legislation

 The Export Control Act 2002 and Export Control Order 2008 place statutory requirements on the UK government.

The Export Control Act 2002 requires collection of information on licences.

Under the Export Control Order 2008 anyone in the UK wishing to export controlled goods must have one of the following:

• a valid licence

• meet the terms and conditions of an OGEL

Exporters or traders must get licences for:

• the export of controlled goods from the UK

• the transhipment of controlled goods through the UK

• trafficking and brokering of controlled goods from within the UK

• the provision of technical assistance

• the provision of financial assistance

Contact

Email [email protected] if you have any comments, feedback or queries about licensing statistics quality and methodology.