Export controls: torture and capital punishment goods
Source: gov.uk (2025-09-08)

Export controls on goods that can be used for torture or capital punishment.

Goods are subject to export prohibitions or controls from the UK if they can be used for:
- torture
- capital punishment
- cruel and inhuman or degrading treatment or punishment
These goods are controlled by the Torture Goods Regulations.

Goods controlled by the Torture Goods Regulations include drugs used in executions by lethal injection. The export of pancuronium bromide and propofol to the United States is also controlled under UK legislation.

Legislation

In Great Britain, the following regulations apply:

The assimilated Regulation (EU) 2019/125 of the European Parliament and of the Council (https://www.legislation.gov.uk/eur/2019/125/contents).

Exports from Great Britain to EU member states may require a licence, depending on the type of goods.

In Northern Ireland, Regulation 2019/125 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R0125-20210101) applies. This has most recently been amended by Commission Delegated Regulation (EU) 2025/928 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32025R0928).

Exports from Northern Ireland to EU member states do not require a licence (except in specific circumstances).

Exports from Northern Ireland to Great Britain require a licence.

Associated secondary legislation

Licensing, enforcement and penalties powers are in the Export Control Order 2008 (https://www.legislation.gov.uk/uksi/2008/3231/contents) (as amended).

How the Torture Goods Regulations affect exporters

Regulating trade in certain kinds of equipment

The Torture Goods Regulations list 3 categories of goods:
- those which have no practical use other than for the purposes of capital punishment, torture and other cruel, inhuman or degrading treatment or punishment
- those that have legitimate law enforcement applications but could be used for the purpose of torture or other cruel, inhuman or degrading treatment or punishment
- those that could be used for the purpose of capital punishment
The export of the first category of goods is prohibited, except in specific circumstances.

The other 2 categories of items may be authorised by export licence.

Goods that are prohibited

Annex II (https://www.legislation.gov.uk/eur/2019/125/annex/II) of the Torture Goods Regulations lists goods which have no practical use other than for the purposes of capital punishment, torture and other cruel, inhuman or degrading treatment or punishment.

Any export or import of these goods is prohibited. The supply of technical assistance in connection with these goods is also prohibited.

These goods include:
- gallows and guillotines
- electric chairs for the purpose of execution of human beings
- airtight vaults
- automatic drug injection systems
- electric shock devices, thumb-cuffs, finger-cuffs, thumbscrews and finger-screws
- bar fetters, leg restraints and gang chains
- cuffs for restraining human beings
- restraint chairs
- shackle boards and shackle beds
- cage beds
- net beds
- batons or truncheons with metal spikes
- whips with multiple lashes or fitted with barbs, hooks or spikes
An exemption from this export prohibition can only be made if the goods are to be exhibited in a public display in a museum because of their historic significance. If this exemption applies, you will need an export licence, from the Department for Business and Trade (DBT).

Goods that require an export authorisation

You will need a licence from DBT to export the goods listed in Annex III (https://www.legislation.gov.uk/eur/2019/125/annex/III) and Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV) of the Torture Goods Regulations. The supply of brokering services and the supply of technical assistance in respect of the goods listed in Annex III (https://www.legislation.gov.uk/eur/2019/125/annex/III) or in Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV) to the Torture Goods Regulations is also subject to authorisation.

Annex III (https://www.legislation.gov.uk/eur/2019/125/annex/III) of the Torture Goods Regulations lists goods that could be used for the purpose of torture or other cruel, inhuman or degrading treatment or punishment, but also have legitimate applications, for example:
- shackles and gang-chains, certain individual cuffs or rings
- spit hoods
- portable electric shock devices
- devices for the purpose of riot control or self-protection by the administration or dissemination of an incapacitating chemical
- certain pepper sprays
For the Torture Goods Regulations an export licence is not required for goods listed in Annex III (https://www.legislation.gov.uk/eur/2019/125/annex/III) when:
- the goods only pass through the territory of the United Kingdom, for example, goods which are not assigned a customs approved treatment or use other than the transit procedure within the meaning given by paragraph 5 of Schedule 2 to the Taxation (Cross-border Trade) Act 2018, including storage of goods in a free zone
- the export is to other countries, provided that the goods will be used by the military or civil personnel of the UK, if they are taking part in a UN peace-keeping or crisis management operation in the country concerned, or in an operation based on agreements between the UK and another country in the field of defence
Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV) of the Torture Goods Regulations lists goods that could be used for the purpose of capital punishment, but also have legitimate medical applications.

An export authorisation for goods listed in Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV) is not required where the goods only pass through the territory of the UK, goods which are not assigned a customs approved treatment or use other than the transit procedure within the meaning given by paragraph 5 of Schedule 2 to the Taxation (Cross-border Trade) Act 2018, including storage of goods in a free zone.

Export controls in relation to other regulatory controls for drugs

Exporters should be aware that other regulatory controls applying to the supply or export of these drugs are included under the Misuse of Drugs Act 1971 (as administered by the Home Office).

It is an exporter’s responsibility to ensure that all regulatory requirements are complied with and to apply for licences from all individual relevant regulatory authorities, as necessary.

Additional UK controls on drugs

Article 4A (https://www.legislation.gov.uk/uksi/2008/3231/article/4A) of the Export Control Order 2008 (https://www.legislation.gov.uk/uksi/2008/3231/contents) controls the export of the drugs pancuronium bromide and propofol to the USA.

Pancuronium bromide and propofol are included on the list of human and veterinary medicinal products that are prohibited for export to the USA when they are in a form suitable for injection, or for preparation of an injection.

Any person seeking to export these drugs from the UK to the USA requires an export licence issued by DBT.

A licence will be refused if the end-use is execution or if we consider that there is an unacceptable risk that the drug will be diverted for use in execution. The control covers both direct and indirect export of products from the UK to the USA. The indirect control applies when the initial destination is not the USA, but the exporter knows that the goods will be re-exported, and that the ultimate destination is the USA.

Apply for an export licence

Check whether the goods you propose to export are controlled under these Regulations and whether they require a licence.

For the export of drugs controlled under Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV) of the Torture Goods Regulation, check if your export is subject to other licensing requirements administered by either the Home Office, the Medicines and Healthcare Regulatory Agency (MHRA) or the Veterinary Medicines Directorate (VMD).

General Export Authorisation (GEA)

Article 20 (https://www.legislation.gov.uk/eur/2019/125/article/20) of Torture Goods Regulation creates a General Export Authorisation (https://www.gov.uk/government/publications/general-export-authorisation-trade-in-torture-goods) (GEA), which has the same status as open general export licences (OGELs) issued under UK export control law.

The GEA is described in Annex V (https://www.legislation.gov.uk/eur/2019/125/annex/V) of the assimilated Torture Goods Regulations, and it can only be used for goods listed in Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV).

Part 3 (https://www.legislation.gov.uk/eur/2019/125/annex/V/part/3) of Annex V lists the conditions and requirements which you will need to satisfy to use the GEA. To meet the requirement for an end-user declaration under Part 3(1)(f) of Annex V you should obtain the End-user Undertaking (EUU) in the following format: GEA undertaking template (https://assets.publishing.service.gov.uk/media/5fe1b461d3bf7f0897f24666/GEA_undertaking_template.pdf) (PDF, 149 KB, 3 pages).

Once you have determined that you can use it, you can register for a GEA (https://www.spire.trade.gov.uk/spire/fox/espire/LOGIN/login). You must register to use the licence.

A GEA is not required for exports from Northern Ireland to the European Union of goods listed in Annex IV (https://www.legislation.gov.uk/eur/2019/125/annex/IV).

Standard individual export licence (SIEL)

If your proposed export is to a destination not permitted under the GEA, you will need to apply for a standard individual export licence (SIEL).

You also need to apply for a SIEL when the export is to a destination permitted under the GEA, but you know that the ultimate destination is not permitted.

Apply for a SIEL (https://www.gov.uk/guidance/apply-to-export-controlled-goods).

The completed application should be supported by an end-user and stockist undertaking (EUSU). The EUSU should be signed and dated by a person authorised by the end-user or stockist to sign on their behalf (this person is the responsible official).

The EUSU should explain:
- from whom the goods have been ordered (the UK exporter)
- to where and whom the goods are to be consigned
- description and quantity of goods ordered
- for what end-use the goods are intended and by whom
- that the goods are not intended for re-export or re-transfer from the end-use destination
- that the goods are not intended for use in carrying out of execution by lethal injection and will not be re-exported or otherwise sold or transferred if it is known or suspected they are or are likely to be used for such purposes
There’s guidance on what should be included in the EUSU (https://www.gov.uk/government/publications/end-user-undertaking-euu-form/end-user-undertaking-euu-form-guidance).

All applications for a SIEL will be assessed on a case-by-case basis.

Compliance checks

If you are granted a licence, you will be subject to compliance checks conducted by the ECJU Compliance Unit.

Find out more about compliance checks (https://www.gov.uk/government/publications/compliance-visits-explained).

Contacts

ECJU helpline

General queries about strategic export licensing

Export Control Joint UnitDepartment for Business and Trade Old Admiralty Building Admiralty PlaceLondonSW1A 2DY

Email xxx@xxx.xx (mailto:xxx@xxx.xx)

Telephone xx-xxxx-xxxx

Home Office Drugs Licensing and Compliance Unit

Telephone: xx-xxxx-xxxx (commercial applicants) or xx-xxxx-xxxx (personal applicants)