COMMUNICATION FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT The Review of export control policy: ensuring security and competitiveness in a changing world
Date: 2014-04-24
Institutions: European Commission
Subjects: competitiveness, dual-use good, export (EU), export monitoring, illicit trade, nuclear non-proliferation, public safety, trade restriction, weapon of mass destruction













EUR-Lex - 52014DC0244 - EN











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52014DC0244

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT The Review of export control policy: ensuring security and competitiveness in a changing world /* COM/2014/0244 final */









COMMUNICATION
FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT
The Review of export control policy:
ensuring security and competitiveness in a changing world

1.     
Introduction

The EU is a major producer and
exporter of dual-use items and therefore a significant actor in counter-proliferation
export controls.
The EU export control regime emerged in the late 1990s and was gradually strengthened
over the last decade,
in particular in response to the EU Strategy against the proliferation of
weapons of mass destruction (WMD) of December 2003. Regulation (EC) No 428/2009[1]
(hereunder 'the Regulation') implements international commitments under United
Nations Security Council Resolution (UNSCR) 1540 (2004), as well as relevant international
agreements and multilateral export control regimes. The Regulation enables
the free circulation of dual-use items – with some exceptions – inside the EU
and lays down basic principles and common
rules for the control of the export, brokering, transit and transfer of dual-use
items. 
Article 25 of the Regulation
calls on the Commission to review its implementation and present proposals for
amendments. Moreover, ten years after the adoption of the EU Strategy against
WMD proliferation, the Council recently called for the continued pursuit of an
effective EU WMD counter-proliferation policy and for a review and
strengthening of export controls[2]. As a first step
toward preparing the review, the Commission issued a Green Paper[3] launching a broad
public debate concerning the EU export control system and, in
January 2013, published a Staff Working Document[4] identifying the main
issues raised by over 100 stakeholders, including their views concerning
possible evolutions towards a more integrated EU export control regime ensuring
security and a more level-playing field. A report to the European Parliament
and Council on the implementation of the Regulation was adopted on 16 October
2013[5], marking a second
step in the review process. The present Communication aims at mapping the direction
for EU export controls, and identifies concrete policy options for their modernisation
and their adaptation to rapidly changing technological, economic and political
circumstances.
This Communication has also been
identified as an intiative under the Regulatory Fitness and Performance
Programme (REFIT).

2.     
Export
controls in a changing security, technological and economic environment: the
need for an export control policy review 

The global counter-proliferation
system has developed considerably since the turn of the century, and robust
barriers have been erected against proliferation. Export controls constitute a
key instrument in the counter-proliferation
toolbox but they must keep pace with evolving proliferation threats,
rapid technological and scientific developments and transformations in global
economic activity that create new security challenges and impacts
on the global level-playing field.

2.1. Evolving and new security
risks and threats 
 There are growing
     WMD proliferation challenges and WMD proliferation still constitutes one
     of the greatest security risks for the EU, especially as an increasing
     number of states
     are developing capabilities of proliferation concern.
     Trade in sensitive items is therefore likely to remain a crucial pathway
     to outfit covert proliferation programmes in future.


 Globalisation
     and the increasing activity of non-state
     actors involved in clandestine proliferation
     programmes lead to a confluence of transnational
     security threats whereby illicit activities converge and a drug trafficker may also act as a terrorist or a
     proliferator. The terrorist threat
     and
     vulnerability
     to unconventional attacks continue to require special
     attention,
     notably due to the changing profile of terrorists and the
     globalised nature of terrorism. 


 Proliferators
     are dynamic and devise evolving proliferation strategies to
     exploit the vulnerability of the interconnected
     global trading and information systems. They elaborate techniques to evade
     controls
     using
     increasingly sophisticated support networks characterised
     by
     the presence of a variety of non-state actors (including unsuspicious
     legitimate operators such as suppliers unfamiliar with proliferation
     risks, financing agencies, transport operators, scientific and academic
     bodies) and
     moving
     sensitive items through areas with weak domestic institutions and trans-shipment
     hubs.


2.2. Rapid technological and
scientific developments
 Innovation
     and the spread of technological advances play a key role in the emergence
     of new proliferation risks: the security of governments, but also of
     companies and citizens, has a growing technological component. New
     technologies put weapons design and manufacture within the reach of a
     larger group of persons, thereby multiplying threats. Furthermore, the
     rapid diffusion of information technology is exposing modern economies to
     new risks induced by the connectivity associated with global trade and
     global data networks - including the emergence of
     specific "cybertools" for mass surveillance, monitoring,
     tracking and interception. Cyber-security
     is now crucial for the security of the EU and "cyber-proliferation"
     has become an important dimension of export controls.


 Exports are
     increasingly transmitted, not transported. In
     the age of cloud computing, information flows containing sensitive
     technology can be used to produce unlimited quantities of
     sensitive goods and present
     a major challenge for export control, especially due to
     the inapplicability of border controls, and the difficulty for companies
     to ensure compliance (e.g. with respect to IT architecture, engineering
     collaboration, travel of experts etc). Export
     controls thus need to operate 'online' in the context of a globally
     connected world, in which intangible technology transfers (ITT)[6]
     have become increasingly significant vis à-vis the physical
     movement of goods. 


 Scientific research
     leads to extraordinary advances that benefit society, but the risk that research
     could be misused creates a growing tension between the
     principle of openness in science and security concerns.
     Debates have highlighted the need to take into consideration the global
     nature of science and the free flow of scientific
     information[7],
     but have also emphasised the need to address the risk
     associated with potential abuse of scientific research and to ensure
     independent assessment of the security implications.


2.3. Global supply chains
and the level-playing field 
 Security
     has become a key element for responsible supply chains. Export
     controls need to protect legitimate trade from the risks associated
     with illicit transactions at a time when trade flows are
     becoming more complex and vulnerable, as a more
     rapid and dematerialized global trade emerges from the multiplication of
     cross-border flows of goods, investment, services,
     know-how
     and people associated with international production networks. The
     use of intermediaries, front companies, diversion and transhipment points
     have multiplied the number and types of actors and activities involved in
     proliferation-sensitive transfers. The
     development of on-line services and e-commerce adds
     new challenges as digital trade must remain open and secure. 


 The
     rise of global value chains and expanding international manufacturing
     capacities lead to an increasing foreign availability
     of dual-use items. The ownership and operation of dual-use industries is
     increasingly internationalised and there is now a remarkable variety of
     actors involved. This fundamentally affects
     the notion of "supplier" which lies at the core of the export
     control and illustrates the need for flexible export controls adjusting to
     changing economic realities.


 The
     profile of high-technology industries is also changing. The blurring
     of civilian and defense technology and
     industrial bases and the multiplication of items with uncertain dual-use
     features make it increasingly difficult to distinguish
     between
     purely civilian or dual-use transfers. As a result, dual-use trade has
     steadily increased over the years to represent a sizeable portion of external
     trade[8].
     Its
     wide-ranging sector and product ramifications create
     operational challenges due to the growing volume and diversity of
     applications. 


 Export
     controls represent a key competitive factor, as Europe's economy
     shifts towards innovative high value-added manufacturing, and European
     value chains are integral parts of global value chains. In
     this context, differentiated levels of controls in third countries create
     distortions of competition to the detriment of EU companies operating
     globally. Also, some remaining divergent control parameters and instances
     of "asymmetric implementation" of controls may occasionally
     affect the consistent implementation of controls and the level-playing
     field within the EU. 


3. Beyond materiality and
borders: towards an integrated risk-based strategic trade control system.

With
the current
export control regime, the EU has tried to strike a balance between security
and trade. The system is generally considered robust and
effective and
provides solid legal and
institutional foundations. But it cannot remain
static: it must be re-evaluated and upgraded in order to face
new challenges
and generate
the modern control capabilities the EU needs for the coming decade and beyond.
This could be achieved by giving new impetus to the development of
an integrated risk-driven strategic trade control model, based on the following
directions:

 A risk-based
     review of the balance between the necessity of trade regulation and the
     reduction of regulatory burdens to ensure that legislation is clear and proportionate.
     Non-regulatory actions - guidelines, pooling of resources etc. - could
     also be envisaged to equip the EU control regime with flexible tools to
     respond to new challenges while ensuring a level playing field in the EU
     internal market.


 An
     integrated approach to enhance the coherence of all export control "pillars"
     (legislation, pre-licensing, implementation, enforcement, outreach)
     through
     the development of a common EU control network supporting
     a greater
     focus on consistent implementation and enforcement with a view to reducing
     distortions of competition and improving security. 


 Transparency
     and engagement with stakeholders and a more prominent role for the private
     sector would be key to an integrated approach allowing operators to fully
     play their complementary roles, thereby optimising the use of resources
     and supporting effective compliance. 


 Proliferation
     is carried out in an international context and export control policy needs
     to include an international dimension.
     The
     development of an integrated system would allow more active EU external action,
     strengthening multilateral processes that constitute the core of the global
     export control system while also providing a basis for mutually beneficial
     relations with key partners. This, in turn, would strengthen the EU's own
     security.
3.1. Priority 1: Adjust to
an evolving security environment and enhance the EU contribution to
international security 

The EU export
control system must
respond
to shifting foreign policy considerations and keep pace with new approaches
to security. It needs to integrate the security implications of an
ever growing number of emerging technologies and a broader
range of dual-use items, in order to ensure their peaceful use. It needs to move
beyond the increasingly artificial divide between internal and external
security and tackle evolving proliferation risks
that move across borders and jurisdictions.
·        
The
Commission will consider evolving towards a "human security"[9]
approach recognising
that security and human rights are inextricably interlinked. This
may involve evolving towards a notion of 'strategic' items addressing not only
and strictly, items with possible military and WMD proliferation end-uses, but
taking a wider security approach. This may also imply a clarification of
control criteria to take into consideration broader security implications,
including the potential effect on the security of persons e.g. through
terrorism or human rights violations. This approach would also strengthen the
coherence with other security trade controls and converge with international
trends, e.g. the Arms Trade Treaty (ATT)[10] and
the UN Firearms Protocol.
·        
The
Commission will consider developing a "smart security" approach to
adjust to the transformations of dual-use items and
the proliferation of new technologies and address the increasing complexity of
the international supply chain. This may involve consideration of the following
options:

 Development
     of an "EU technological reaction capacity" for an active contribution
     to the highly technical discussions of control lists, but also to ensure
     rapid reaction to the challenges posed by emerging technologies (such as
     cloud
     computing, additive manufacturing
     (3-D printing), nanotechnology) as well as de-control
     of items that have become obsolete or widely
     available commercially. This mechanism could build upon the expertise
     available within export control authorities and on structured engagement
     with industry. It may also imply developing
     guidance where technologies represent a key development for business that
     presents risks and calls for transparency, legal clarity and a common approach.


 Design of an
     effective EU response to the use of cyber-space for proliferation
     activities and clarification of controls of cybertools[11].
     This may imply EU actions to promote multilateral decisions on cyber-tools,
     or alternative options such as the introduction of EU autonomous lists or
     a dedicated catch-all mechanism, without hindering the competitiveness of
     the EU information and communication technology (ICT) industry and its integration
     into global supply chains. 


 Modernised
     control approaches addressing the porosity of legal and illicit trade may include options for strengthening the legal basis
     and upgrading certain control modalities in order to cover all aspects and
     actors in the chain of controls and address divergent applications of
     controls and related vulnerabilities. This may involve clarifying the notion
     of export and exporter to capture the variety of activities and actors
     involved in global supply chains, reviewing the determination of the
     competent authority (especially for non-EU companies), updating the
     control of technical assistance, enhancing the consistency and enforcement
     of brokering and transit controls as well as introducing specific legal
     provisions to counter circumvention and address transactions involving EU
     persons irrespective of their location. Furthermore, options regarding the
     introduction of new control modalities and the partnership with the private
     sector could contribute to shifting emphasis on end-use monitoring and facilitate
     legitimate exports and the detection of illicit trade.

·        
The
Commission could examine options to promote a specific strategy to ensure
"immaterial control" and address the challenge posed by Intangible
Transfers of Technology (ITT), including the need to clarify the control
of 'dual-use research', while avoiding undue obstacles to the free
flow of knowledge and the global competitiveness of EU science and technology. 

 The clarification
     of the legal framework applying to ITT may involve reviewing legal
     provisions and/or providing guidance relating to basic notions applying to
     electronic transfers of controlled technology. It may also concern the control
     modalities and the introduction of specific tools to facilitate the free
     flow of technology (e.g. EU General Export Authorisations (EUGEAs) for
     intra-company research and development) while enhancing ITT traceability
     and enforcement through an approach shifting the focus on pre-transfer
     control provisions - e.g. registration, self-auditing - and post-transfer
     monitoring - e.g. compliance audits - rather than on the transmission
     itself;


 Targeted
     and coordinated outreach for academic research communities throughout the EU
     could raise awareness about applicable rules and promote effective
     implementation by scientists
     and laboratory workers. Other options such as the preparation of a code of
     conduct for scientists engaged in the performance of dual-use research
     could also be envisaged.
3.2. Priority 2: Promote export
control convergence and a global level-playing field

In spite of the
growing international recognition of export controls, differentiated control
standards in third countries create distortions of competition and weak links
in the global supply chain that proliferators can take advantage of. EU policy
should therefore promote convergence towards global and effective controls for
global supply chains, in order to remove the challenge for industry of
concurrent compliance with differing regulations and support a level playing-field.

 The
     Commission could consider setting up an effective mechanism for a regular
     update of EU control lists drawing on expertise from national authorities,
     to ensure that control lists are in tune with technological
     and commercial developments and minimise distortions of competition associated
     with outdated controls.


 Although the
     EU licensing architecture is generally considered satisfactory, licensing
     processes continue to impact competitiveness. The Commission will therefore
     seek ways to optimise the licensing architecture and processes in
     order to avoid burdensome licensing procedures
     and to minimise delays and distortions
     of competition. This could include options for the:

o  
Introduction
of a system for a regular review of National General Export Authorisations (NGEAs)
and discussion of their possible transformation into EUGEAs and extension to
the whole EU;
o  
Shift
towards open licensing through the introduction of additional EUGEAs, reviewing
the balance between efficiently acting to counter proliferation and reducing the
burden for licensing authorities and exporters through a proportionate level of
control, e.g.:
§  "Low
Value Shipments" to facilitate export of small quantities of items presenting
a low proliferation risk;
§  "Encryption",
to allow the export of ICT items which are widely used in industrial processes
and operate in a highly competitive environment;
§  "Intra-company
technology transfers" for research and development purposes;
§  "Intra-EU
transfers" for Annex IV items[12],
allowing for control modalities that do not hinder the free-flow of goods and
technology within the Single Market;
§  "Large
projects" allowing authorities to look at the "bigger picture"
rather than an accumulation of individual licensing applications.
o  
Review
of the parameters (destinations, items) for existing EUGEAs to ensure that they
are up-to-date, and harmonisation of some licensing conditions and requirements
in order to promote consistent implementation throughout the EU, including the
validity period of individual licences and of denials. Preparation of
guidelines for consistent licensing practices, including best practices e.g. on
processing times, could also be considered.

 The Commission
     will assess options to promote the global convergence of export controls
     with a view to facilitating trade in dual-use items. This could include actions to promote coherent, comprehensive and unified
     EU representation in the regimes[13] as a reflection of its role in counter-proliferation and trade. It could also involve pursuing active external outreach
     and cooperation to assist partner countries in developing convergent
     regulations, as well as developing export control dialogues with key
     trading partners with a view to avoiding conflicting regulatory
     requirements and reducing the administrative burden on export-oriented
     industries.
3.3. Priority 3: Develop an effective and
competitive EU export control regime 

The multilevel
structure of EU export controls provides for a unique and flexible system, but instances
of divergent application may occasionally compromise their overall
effectiveness. The Commission should thus assess
options to address
the "asymmetric implementation" of controls in order to minimise
distortions of competition and transactions costs associated with controls within
the EU.
·        
Divergent
control decisions are often attributed to a perceived lack of harmonised EU
export control policy and especially to a divergent risk assessment underlying
control decisions. A risk-based approach, based on the development of a common
risk management framework could ensure greater consistency in the
identification of high-risk transactions while optimising the EU-wide use of
resources and reducing distortions of competition due to divergent control
decisions. 
·        
Catch-all
controls[14]
remain essential tools to prevent the use of non-listed items for
proliferation, but uneven implementation has raised concerns in terms of legal clarity,
distortions of competition and potential weak links in the chain of controls. A
greater convergence could be achieved through the harmonisation
of the notion of catch-all controls and the strengthening of consultation to
ensure their EU-wide application and reinforce a policy of no-undercutting. This
could be supported by regular exchange of information and the establishment of an
EU catch-all database. Some information could be shared with customs and other
agencies in order to enhance enforcement, or be made available publicly. Transparency
can support operators' due diligence to ensure that the supply chain is secure.

·        
The
Commission could assess options for a critical re-evaluation of intra-EU
transfer controls in order to minimise remaining barriers in the Single Market,
while keeping strict controls on the most sensitive dual-use items. This could
include a review of Annex IV to focus on an updated list of most sensitive
items and/or the introduction of an EUGEA for intra-EU transfers, including
technology transfers. Appropriate conditions and requirements, including options
for post-shipment verification within the EU, could be designed to compensate
for the removal of pre-transfer licensing and to ensure the security of
transfers and the availability of information.

3.4.
Priority 4: Support effective and consistent export control implementation &
enforcement 

Export control
policy should not only focus on setting rules for the control of legitimate
trade, but also consider the pre-emption and disruption of illicit trade. Consistent
implementation and enforcement across the EU is essential to address the risk
of evasion of control processes, but a lack of solid EU-wide
statistics and intelligence still hampers effective policy and operational
responses. The Commission will review the following options to develop a more
integrated implementation and enforcement framework:
·        
With
over 40 000 applications per year, export controls are demanding in terms
of administrative resources within control authorities. The development of an EU
export control network could strengthen the overall capacity of the system
while optimising the use of resources and keeping administrative costs under
control, through the following options:

 Enhanced structured
     exchange of information between export control authorities on
     licensing data as well as other relevant information (e.g. destinations,
     end-users, incidents and violations) could allow access to critical
     information for all competent authorities, based on clearly identified
     needs in order to avoid information overload. The secured IT
     infrastructure "DUeS"[15]
     could be expanded to support enhanced information sharing.


 Enhanced
     strategic and operational cooperation with enforcement agencies, e.g.
     customs, could be achieved by ensuring integration of export
     control priorities in relevant policy cycles[16],
     by sharing information through an EU-wide exchange system, developing
     common risk management tools and implementing joint operations. Targeted information
     exchange on enforcement activity would allow a better strategic overview
     of the effectiveness of controls across the EU and the sharing of best
     practices, and could feed back into policy formulation e.g. for the
     detection of illicit trade. 


 Improved coherence
     between different EU institutions and Member States and the identification
     of
     synergies between security-related trade control instruments,
     e.g. through the development of a common IT infrastructure as a shared
     platform to support exchange of information across the EU, could increase
     the overall impact of EU counter-proliferation actions.
     Coherence with other closely-related EU policies and regulations, e.g.
     under the EU Action Plan on chemical, biological, radiological and nuclear
     security, Regulation (EU) N° 98/2013 on explosive precursors and
     Regulation (EU) N° 258/2012 on firearms should also be ensured.


 The past
     decade has seen extensive capacity-building on WMD-related matters,
     including significant export control outreach programmes to third
     countries, while initiatives within the EU are still at their early
     stages. The development of a targeted EU-wide capacity-building
     programme and training for relevant officials, including customs
     and border agencies, could increase capacity to prevent and detect
     cross-border trafficking of strategic items. The
     pooling of expertise e.g. through the further development of the "Pool
     of experts", could also strengthen the EU chain of control.

·        
In
modern economies, the private sector plays the most crucial role in the control
chain. Therefore, partnerships with the private sector could greatly
enhance the security and resilience of the global supply chain. Operators
are well-placed
to spot illicit trade and protect sensitive technology, while uneven
trade compliance creates trade distortions and opens opportunities for the
exploitation of weak points in supply chains. The creation of these conditions
relies on better coordination and understanding between governments and the
private sector
and could imply various actions such as:

 Compliance efforts could be recognised through
     the facilitation of control and fast-track export
     processes
     by setting clear private sector compliance
     standards for use of simplified mechanisms (such as EUGEAs, NGEAs, Global Licences) as a substantial
     privilege granted to reliable exporters. This may include legal requirements and/or guidelines for
     operators
     to
     identify, manage and mitigate their risk of exposure to proliferation by
     undertaking enhanced vigilance for items of high proliferation concern through
     due-diligence
     and disclosure requirements, including the reporting of suspicious
     transactions. While costs for business should be minimised and
     self-regulation encouraged, standard requirements for 'Internal Compliance Programmes'
     (ICPs) could support a level-playing field within the EU. Compliance and
     competitiveness are mutually reinforcing, as compliance reduces
     the risk of inadvertent supply of dual-use items to programmes of concern
     that exposes firms to penalties and reputational damage.
     Furthermore, options to promote convergence with customs'
     "trusted operators" programme
     (AEO) could reduce duplication of controls and offer cost-effective
     avenues for both operators and administrations. 


 Transparency
     and
     coordinated outreach could be critical steps to provide clarity on
     requirements, support operators'
     compliance efforts and improve their capacity
     to implement controls, thereby
     creating conditions in
     which each element of the supply chain is
     resistant to "contamination" by illicit trade. This could
     involve the
     publication of reports
     and non-sensitive control information, including guidance promoting
     good compliance practices.


 The
     development of common EU support tools for economic operators e.g. standardised IT tools and
     electronic licensing systems, could also support
     compliance efforts by companies.

·        
Export controls reflect international commitments and represent
a key safeguard for the integrity of international trade and it is therefore
essential to enhance their global effectiveness. Options for the co-operative implementation of controls with external
partners could be examined to facilitate a secure trade in strategic items,
e.g. through the development of end-use monitoring of third-country companies,
as well as the mutual recognition of assessments.

4. Conclusion

Economic
operators, Member States and citizens in the EU all have an interest in
effective export controls, ensuring security by combating illicit trade while
facilitating legitimate trade. An updated EU approach and regulatory framework
will reinforce the security and integrity of the supply chain. This will
require a more systematic exchange of risk information and coordination between
licensing and other authorities as well as engagement with the private sector
and closer international cooperation.
Before taking
concrete initiatives for action, the Commission invites the Council and the
European Parliament to consider the approach set out in this Communication. In
parallel, the Commission will conduct an impact assessment of the review
options outlined in this Communication to identify the most suitable regulatory
and non-regulatory actions to bring them into effect. With reference to REFIT,
the Commission will assess the costs and benefits associated with the various
options, notably as regards potential regulatory simplification and burden
reduction.
_______________
List
of acronyms
 ATT || Arms Trade Treaty 
 DUeS || Dual-Use Electronic System 
 EU || European Union 
 EUGEA || EU General Export Authorisation 
 ICP || Internal Compliance Programme 
 ICT / IT || Information (and Communication) Technology 
 ITT || Intangible Technology Transfer 
 NGEA || National General Export Authorisation 
 REFIT || Regulatory Fitness and Performance Programme 
 WMD || Weapons of Mass Destruction 
 UNSCR || United Nations Security Council Resolution 
[1] OJ L 134, 29 May 2009,
p. 1.
[2] Council
Conclusions on ensuring the continued pursuit of an effective EU policy on the
new challenges presented by the proliferation of weapons of mass destruction
(WMD) and their delivery systems, 21 October 2013.
[3] COM(2011)
393 of 30 June 2011.
[4] SWD(2013)7 of 17
January 2013.
[5] COM(2013) 710 of 16
October  2013.
[6] Intangible
technology transfer includes both the transfer of technical information via
electronic means and the transfer of knowledge and skills by persons.
[7]  C(2012) 4890 final on access to and preservation of scientific information.
[8] EU controlled dual-use
exports are estimated to value approximately 2.5% of EU total exports. For more information
on EU dual-use trade, please refer to COM(2013) 710 final.
[9] The "human security
approach" intends to place people at the heart of EU export control
policy, in particular by recognising the interlinkages between human rights, peace
and security.
[10] The ATT aims at
reducing illicit arms trade by setting transparency rules and common ethical
standards for the international trade of conventional weapons.
[11] See as well the joint
communication to the European Parliament, the Council, the European Economic
and Social Committee and the Committee of the Regions on "Cybersecurity
Strategy of the European Union: An Open, Safe and Secure Cyberspace", 
JOIN(2013) 1 final, 7 February 2013.
[12] Annex IV to
Regulation (EC) N° 428/2009 lists particularly sensitive dual-use
items subject also to intra-EU transfer
controls.
[13] See, for example,
General Arrangements on EU Statements in multilateral organisations,
doc.15901/11,  24 October 2011
[14] So-called
"catch-all controls" apply to non-listed dual-use items with
potential military or proliferation end-use.
[15] Dual-Use Electronic System
[16] In relation
specifically to customs, the development of a new Strategy and Action Plan
on risk management and supply chain security requested by the Council on 18th
June 2013 provides a key opportunity to consider how an enhanced Common Risk
Management Framework for customs controls can best be exploited to support
customs-licensing collaboration, enforcement and trade facilitation for the
future.