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Following the entry into force of the new EU Dual-Use Regulation 2021/821 last month (see also our recent post), the EU has introduced new document codes that need to be used on EU customs export declarations for exports and transits of dual-use items.

Notably, specific codes now apply depending on the relevant (type of) authorisation/licence. The old code “X002” (which was previously valid for all dual-use authorisations) has been replaced and cannot be used anymore. The new document codes are:

Type of authorisationDocument code
Individual export authorisation 
Individual authorisationX060 
Union General Export Authorisation (UGEA) 
UGEA EU001X061 
UGEA EU002X062 
UGEA EU003X063 
UGEA EU004X064 
UGEA EU005X065 
UGEA EU006X066 
UGEA EU007X067 
UGEA EU008X068 
Global export authorisation 
Global authorisationX070 
National General Export Authorisation (NGEA) 
NGEAX071 
Transit authorisation 
Transit authorisationX072 

As before, the applicable document code needs to be included in box 44 of the Single Administrative Document (SAD), together with other relevant details. Exporters are advised to review the document codes that apply to their authorisations/licences and implement necessary updates, both internally and externally (e.g. vis-à-vis freight forwarders and logistics providers), as appropriate.

Author

Christiaan van der Meer joined Baker McKenzie’s Amsterdam office in 2005, where he is now a senior associate practicing EU and Dutch competition law. He has worked in the European & Competition Law Practice of the Firm’s Brussels office between 2009 and 2011.

Author

Derk Christiaans is an associate in the Competition & Trade department of Baker McKenzie's Amsterdam office and advises (multi)national companies on EU, competition and trade matters in various industries, including healthcare and life sciences, TMT, and consumer goods and retail.

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