The New Item Codes for Declaring Exports of Dual-use Goods

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As of 9 September 2021, the new dual-use Regulation (EU) 2021/821 applies. Regulation 2021/821 brings some significant changes in the field of export controls. One of its aims is to further harmonize EU laws and regulations in this area. Within this framework, new item codes for declaring the export of dual-use goods have now been introduced.

By Bruce van Schaik & Gerard Kreijen,

Regulation 2021/821 replaces Regulation 428/2009 and sets up a new Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.

Item codes must be used when an export declaration is made for dual-use goods. Until 9 September, all exports of dual-use goods were covered by item code X002. This code has been replaced by new item codes. The new codes are linked to the various export licences.

Please find below the item codes to be used henceforth:

– X060 for an individual export licence;

– X061 for Union general export licence EU001;

– X062 for Union general export licence EU002;

– X063 for Union general export licence EU003;

– X064 for Union general export licence EU004;

– X065 for Union general export licence EU005;

– X066 for Union general export licence EU006;

– X067 for Union general export licence EU007;

– X068 for Union general export licence EU008;

– X070 for a global export licence; and

– X071 for a national general export licence.

EU Member States were rather surprised by this change, as it was not announced prior to its implementation in the EU customs system. Nonetheless, to act in full compliance with applicable customs and export control regulations, companies must take care to use from now on the new codes when making export declarations for dual-use goods.


Bruce van Schaik
Bruce van Schaik
Gerard Kreijen
Gerard Kreijen
Bruce van Schaik
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Bruce van Schaik

Bruce van Schaik, tax advisor, is since 2020 a member of Loyens & Loeff’s Indirect Tax practice group and the International Trade & Customs team in Amsterdam. He focuses on advising and litigating in the area of customs, excise, consumption tax and international trade.

Bruce specializes in (European) customs law. He assists in a wide range of issues in the fields of customs, excise, consumption tax and international trade in goods, including customs valuation, classification, (non-)preferential origin and export controls. In addition, his practice consists of advising on other import levies, such as VAT, and conducting legal proceedings before national and European law bodies.

Bruce is a Member of the Dutch Association of Tax Advisors (NOB). He holds a Post-Master in Customs Law and a Master in Fiscal Economics from the Erasmus University Rotterdam.

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