A manufacturer of uncooled thermal cameras in the Lyon area has sold through a distributor in Bristol for ten years. Before 2021 the pallets left on a lorry with a commercial invoice and nothing else. Today the same shipment crosses a customs border, under two export control regimes that no longer share a legislator, and the distributor has started reselling part of the stock to customers in the Gulf. Nobody in either company has asked which licence covers what.
This page sets out, for a French or British business, the rules that apply to dual-use items moving between the European Union and the United Kingdom: what is needed to ship from France to Great Britain, what the British side requires in the other direction, who controls a re-export, and why Northern Ireland follows its own logic. Thermal imaging cameras serve as the running example, because they are a frequent source of questions and sit close to the control thresholds. For the general method of classifying a product, see our analysis of dual-use items and export licences.
1. Since 2021, the Channel is an export border
Until the end of the transition period, a shipment from France to the United Kingdom was a transfer inside the Union. For listed dual-use items it was free, except for the short list of very sensitive items in Annex IV. Since 1 January 2021, Great Britain is a third country for the purposes of Regulation (EU) 2021/821, and every shipment of an item listed in Annex I is an export subject to authorisation (article 3(1)).
The British side has made the same move in reverse. In Great Britain, exports of dual-use items are governed by the assimilated version of Regulation (EC) No 428/2009 and by the Export Control Order 2008. A British company that sends a controlled item to France therefore needs a United Kingdom licence, just as a French company needs a European one to ship it to Bristol. The two control lists were identical in 2021 and are still very close, because both transpose the lists of the international control regimes, but they are now updated by separate acts on separate timetables. The European list in force today results from Commission Delegated Regulation (EU) 2025/2003, applicable since 15 November 2025; the British list was last brought into line by regulations applicable since 16 December 2025.
2. From France to Great Britain: the Union general authorisation EU001
The good news for French exporters is that, in most cases, no individual licence is required. The Union general export authorisation EU001, set out in Section A of Annex II to Regulation (EU) 2021/821, covers exports of almost all Annex I items to Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland including Liechtenstein, the United Kingdom and the United States.
It is not automatic, and its conditions are where exporters slip:
- Excluded items. EU001 does not cover the items listed in Section I of Annex II: all Annex IV items, certain nuclear materials and related software and technology, some biological and chemical agents, and some space launch and missile items. Those require an individual or global licence, even for London.
- Excluded situations. The authorisation cannot be used where the exporter has been informed by the authorities, or is itself aware, that the items are or may be intended for weapons of mass destruction or their delivery systems, for a military end use in a country under arms embargo, or for use as parts or components of military items exported from that Member State without the required authorisation (Annex II, Section A, Part 3, point 1). Nor does it cover exports to a free zone or free warehouse in the destination country.
- The customs declaration. The exporter must state in the export declaration that the goods leave under EU001 (Part 3, point 2).
- Notification. The first use must be notified to the authority of the Member State where the exporter is established, within 30 days of the first export or, where that State so requires, before it (Part 3, point 3). In France, the request goes through the EGIDE platform of the dual-use items service (SBDU), which indicates a processing time of a few days, and users of general authorisations send the SBDU a six-monthly report of the exports made.
In short, a French exporter of a listed thermal camera can usually ship to a British distributor under EU001, provided it has completed the French formalities beforehand, quotes the authorisation in each export declaration and has no information pointing to a prohibited end use. What EU001 does not do is follow the goods once they are in Bristol.
3. Thermal cameras: where the line falls
A thermal camera is not controlled because it is a thermal camera. It is controlled if it meets the technical parameters of entry 6A003 of Annex I. For the uncooled cameras most common in industry, built around a microbolometer detector sensitive between 8 and 14 micrometres, the relevant entry is 6A003.b.4.b, which refers to the focal plane arrays described in 6A002.a.3.f.
Note 3 to 6A003.b.4 then takes out of control cameras that have a maximum frame rate of 9 Hz or less, and cameras combining a set of features designed to make them unsuitable for military use: an instantaneous field of view of at least 2 milliradians, a fixed lens that cannot be removed, no direct view display, and either no facility to obtain a viewable image, a design for a single kind of application not meant to be modified by the user, or a design for installation in a civilian passenger vehicle, solely as a driving aid, with a mechanism that disables the camera once removed from that vehicle. The detail of these conditions matters, and a change of lens, display or frame rate requested by a customer is enough to bring a model back under control. That is exactly the scenario described in our general analysis, and it plays out just as well with a British distributor as with a buyer in Dubai.
Two consequences follow. First, the classification is made model by model, and must be reviewed each time the control list or the product changes. Second, a camera that falls outside the list may still require a licence under the catch-all clause of article 4, if the exporter is informed of, or aware of, a military or weapons-related end use.
4. From Great Britain to France: the British open licence
A British company exporting controlled items to France relies, in most cases, on a United Kingdom open general export licence. In 2026 the British authorities merged the former open licence for exports of dual-use items to EU Member States and the general authorisation GEA001 (the British counterpart of EU001) into a single Open General Export Licence (Export of Dual-Use Items), last revised in October 2026. All EU Member States, including France, appear among its destinations, alongside the United States, Japan, Switzerland and a list of other countries.
Its main conditions are familiar: prior registration with the Export Control Joint Unit, the licence reference on the export documents and in the British customs declaration, records kept for at least four years from the end of the calendar year of export, and acceptance of compliance audits. Some items, including 6A003.b cameras, are excluded for certain destinations under the licence, but not for EU Member States. For a French buyer, the practical point is simple: the British supplier must have registered and must quote the licence. The European regulation does not subject imports of dual-use items to licensing, so a French importer has no licence to apply for on arrival. It should nonetheless keep the supplier’s licence reference and classification in its file: it will need them the day the goods leave the Union again.
5. Re-export: whose rules apply once the goods have crossed
This is where the Bristol distributor’s new Gulf customers become the real subject. The European regulation controls exports from the customs territory of the Union. Once a camera has been lawfully exported to Great Britain, its onward shipment to a third country is an export from the United Kingdom, governed by British law and requiring, where the item is listed, a British licence. The French manufacturer does not apply for that licence, and EU001 does not cover it.
That does not mean the French exporter can look away. Three points deserve attention.
- Knowledge. EU001 is unavailable, and the catch-all clause comes into play, where the exporter is aware that the goods are intended for a prohibited end use. If the distributor’s resales are known to target a sensitive destination, the authorisation under which the first export was made is undermined.
- Russia. Article 12g of Regulation (EU) No 833/2014 requires exporters of certain goods, including the common high priority items of Annex XL, to prohibit contractually any re-export to Russia. The United Kingdom is one of the partner countries listed in Annex VIII, so the clause is not compulsory for a sale to a British distributor. The general prohibition on circumvention remains, and so does the risk attached to a distributor who resells to transit countries. Our analysis of what a French company may still do with Russia sets out the wider framework.
- The contract. Nothing prevents the parties from writing what the law no longer imposes: an end-use statement, a re-export clause requiring compliance with British licensing and prohibiting sales to sanctioned destinations, an obligation to share classification changes, and an audit or information right. These clauses cost little, and they are what a customs officer or a prosecutor will ask to see. See also what a French exporter must be able to prove in 2026.
Conversely, a British company buying controlled goods in France and reselling them outside the United Kingdom must apply British re-export rules, and should check whether its French supplier’s licence or end-use statement contained commitments that bind it.
6. Northern Ireland, a separate case
Under the Windsor Framework, Regulation (EU) 2021/821 continues to apply to and in the United Kingdom in respect of Northern Ireland. The text of EU001 refers to this expressly. The practical result, as described in British guidance, is the following:
- a shipment of dual-use items from Northern Ireland to an EU Member State needs no export licence, and falls outside the British open licence;
- a shipment from an EU Member State to Northern Ireland needs no export licence, except for Annex IV items, which require a transfer authorisation as they would between two Member States;
- according to the same guidance, moving dual-use items between Great Britain and Northern Ireland requires no licence.
The last point is the one that calls for care: goods sent from France to Belfast without any licence can then reach Great Britain without one, and leave Great Britain under British rules. A French exporter whose customer is in Northern Ireland but whose goods are destined for the rest of the United Kingdom or beyond should treat the transaction according to the final destination it knows of, not according to the delivery address.
7. Records, controls and penalties
On the European side, the exporter must keep registers or records of its exports for at least five years from the end of the calendar year in which the export took place (Regulation (EU) 2021/821, article 27). On the British side, the open licence requires four years. In France, an export of a listed item without the required authorisation is a customs offence (export of prohibited goods without declaration) under the customs code as recodified on 1 May 2026, articles L. 512-7 and L. 513-1 and following, with confiscation of the goods and the possible suspension or withdrawal of authorisations; where a sanctions regime is also breached, article L. 542-1 applies. In the United Kingdom, an export in breach of the Export Control Order 2008 is a criminal offence under customs legislation.
A firm that ships regularly across the Channel should therefore have two things on file: a classification of each model against both lists, kept up to date, and a contract with its counterpart that says who obtains which licence and what happens on re-export. For a review of a classification, a distribution contract or a customs file, our customs practice and our sanctions practice work in writing and in English. British companies with other matters in France may also read our page for UK companies after Brexit.
Frequently asked questions
Do I need a licence to ship a thermal camera from France to the United Kingdom?
Only if the model is listed in Annex I to Regulation (EU) 2021/821, typically under entry 6A003.b.4, or if the catch-all clause applies. Where it is listed, the Union general export authorisation EU001 usually covers the United Kingdom, provided the French formalities have been completed, the authorisation is quoted in the export declaration and the exporter has no information pointing to a prohibited end use.
Does EU001 cover the re-export of the goods from the United Kingdom to another country?
No. EU001 covers the export from the Union to the United Kingdom. An onward shipment from Great Britain to a third country is a British export, governed by British law and, for listed items, subject to a British licence obtained by the British exporter.
Must a sale to a British distributor include a no-Russia clause?
Not as a legal obligation: the United Kingdom is a partner country listed in Annex VIII to Regulation (EU) No 833/2014, so article 12g does not apply to it. A contractual clause prohibiting resale to sanctioned destinations is nonetheless advisable, since the prohibition on circumvention still applies.
Is a delivery to Northern Ireland treated as an export?
For dual-use purposes, no export licence is needed from an EU Member State to Northern Ireland, except for Annex IV items. Because goods can then move to Great Britain without dual-use licensing, the exporter should reason according to the final destination it knows of.
How long must export records be kept?
At least five years from the end of the calendar year of export under the European regulation (article 27), and at least four years under the British open licence. A business operating on both sides should apply the longer period.