Background
UK law requires that we record the exports or transfers made under an export licence, including Open General Export Licences (OGELs). In order to fulfil this obligation, please use the Record of Exports form linked on the right side of this page.
The Research Office collates the information you provide, enabling the College to keep a central and auditable record of export activity. The ECJU and HMRC regularly audit licence holders’ export records. Non-compliance with record keeping obligations can result in the revocation of licences.
Guidance for completing and submitting the Record of Exports form
- For longer-term projects we recommend submitting the Record of Exports form on a monthly basis to avoid gaps in the record keeping process. You can download a calendar reminder here:
- Although you must record every physical export in detail, the ECJU does not expect exporters to record each individual email, virtual meeting, phone call, and other intangible exports in the same way. It is sufficient to provide descriptions and approximate quantities of the intangible exports made in the Record of Exports form. However, you must maintain evidence of every intangible export made. For further guidance on this point, please read the following section on information management plans.
- It remains crucially important to comply with any other applicable terms of your export licence, including with regard to recording intangible exports and eligible recipients of those exports. If you have questions about the terms of any licence you are working under, please contact the Research Office for advice.
Information management plans
To help organise and record the thousands of electronic transfers of technology or software, including emails, virtual meetings, or phone calls involving recipients outside the UK, it is advisable to implement an information management plan for such transactions or projects.
This plan regulates how you share controlled items with recipients outside of the UK and provides a clear record of all transfers made. Possible measures include:
- Communicating with the overseas recipient only from a dedicated email address;
- Saving all emails exchanged with the overseas recipient in a dedicated folder within your email client software (Outlook, etc.);
- Keeping notes on all meetings with the overseas recipient;
- Keeping all files shared with the overseas recipient in a dedicated secure storage space (e.g. SharePoint, Microsoft Teams);
- Other measures may be appropriate in specific cases, depending on the nature of the transaction and sensitivity and volume of exports. Please follow guidance provided by the ECJU and contact the Research Office for advice if you have any questions.