A changing world: more export bans and travel bans to contain the spreading of the coronavirus

The rapid spreading of the coronavirus , forces governments and international organisations to take draconic measures: borders are closed, entire countries are on lockdown, (temporary) export bans are imposed on products, such as gloves, masks, face shields and protective clothing and travel bans for entire populations are ordered and enforced by police and military personal. While all of this is happening in the world, regular export control and sanctions continue to evolve and increase. Also, on 17 March 2020, the Dutch government published its monthly overview of approved export-licenses of dual-use goods. This newsletter also contains an analysis of the Dutch “dual use licences”-data of the months January and February 2020 (more about this, at the end of this newsletter).

Coronavirus, export control & bans

In its battle against the spreading of the coronavirus , on 15 March 2020, the EU imposed restrictions on the export of personal protective equipment, such as protective spectacles and visors, face shields, mouth-nose-protection equipment, protective garments and gloves, for a period of six weeks. On 20 March 2020, the EU published guidance on export requirements for personal protective equipment, because of the coronavirus. The EU emphasised the measures are of a temporary nature and not an export ban. On 20 March 2020, the UK published a notice to reassure the British public, that notwithstanding all the measures that are taken to control spread of the Corona virus, export control licences will continue to be processed as before.

Measures by Dutch Customs because of coronavirus

On 19 March 2020 the Dutch Customs Administration announced that because of the outbreak of the coronavirus they have decided to “downscale” some of their activities, where it is possible and responsible to do so. On 23 March 2020 they published a news article, stating that they are taken the necessary measures to enforce the export ban on personal protective equipment, based on EU Regulation 2020/402. Export (which includes export, re-export and inward processing) is only possible if organisations have an export authorisation. The authorisation is issued by the national authority. On that same day – 23 March 2020 – the Dutch Customs announced that because of the coronavirus, the implementation of the new exporter definition is postponed. The Dutch customs previously informed that as of April 2020, only exporters established in the EU should be listed in box 2 of the export declaration. With regard to the postponement, they Customs Authority said the following: “Even after 1 April [2020], you may declare an exporter that is not established in the [European] Union.  We will allow this until the 15th of the month following the month in which government measures against corona[virus] stop”.

Extensions of sanctions by the US and EU

On 12 March 2020 the White House released a statement containing a text of a notice on the continuation of the national emergency with respect to Iran. In the statement the US announced it has renewed its sanctions on Iran for one year by continuing the national emergency declared in Executive Order 12957. The next day, on 13 March 2020, the EU renewed its Russia-sanctions for a further six months until 15 September 2020. The legal acts were published in the Official Journal on 13 March 2020. The sanctions were imposed on Russia because of the undermining of the territorial integrity, sovereignty and independence of Ukraine. In that same week, on 11 March 2020, the EU High Representative for Foreign Affairs and Security Policy, Josep Borrell, welcomed the decision of four countries (Montenegro, Albania, Norway and Ukraine) to join the restrictive EU-measures against Russia. In March 2020 the EU also renewed its sanctions on Egypt for one year until 22 March 2021.

Monthly reporting by Dutch government of export-licenses of dual-use goods

On 17 March 2020, the Dutch government published its monthly overview of approved export-licenses of dual-use goods. This newsletter contains an analysis of the data of the month January and February 2020.

January 2020

In January 2020 the Dutch government issued exactly 100 licenses[1] for dual-use goods, with a total value of EUR 1,066,481,619.06. The average value of a dual-use good was in the month of January: EUR 10,664,816.19. The most expensive license was for the dual-use good “uranium hexafluoride”. Uranium hexafluoride, colloquially known as “hex” in the nuclear industry, is a compound used in the process of enriching uranium, which produces fuel for nuclear reactors and nuclear weapons. The approved license had a value of EUR 696,000,000.00, and the hex was destined for nuclear power plants in Canada, Japan, the United States and South Korea.

The top three of destinations[2] / countries[3] the Dutch export-licenses were intended for in January 2020, were:

  1. China, with 14 by the Dutch government approved licenses,
  2. Saudi Arabia, with 12 licenses, and
  3. Taiwan, with 7 licenses.

Image 1.1 contains a map of the world. The countries where the licences were destined for, are made blue. The darker the colour blue in Image 1.1, the more approved licences the country had in January 2020.

Image 1.1:  Map of the world; overview of number of approved Dutch licences for dual use goods; destinations / countries (January 2020); data based on monthly reporting of exports of dual-use goods of Dutch government.[4]

Afbeelding met berg Automatisch gegenereerde beschrijving

With regard to the kind of products / goods the licenses have been issued for, one can say the following: there were 46 different kind of export licences approved in January 2020, with a total number of 100 licences, hence:

  • 19 out of the 100 licenses where for “Information security equipment, software and technology”;
  • 13 out of the 100 licenses where for “Information security equipment and software”;
  • 6 out of the 100 licenses where for “Information security software and technology”;
  • 6 out of out of the 100 licenses where for “Nuclear Power Plant Technology”.

With regard to the intended purpose of end-use the licenses have been issued for, one can say the following: there were 37 different kind of export licences approved in January 2020, with a total number of 100 licences:

  • 39 times the end-use of the dual-use product was defined as “information security”;
  • 6 times the good was destined for the “chemical industry”;
  • 6 times the good was destined for the “civil aviation”;
  • 6 times the good was destined for the “uranium enrichment”.

Image 1.2 contains a chart with all of the by the Dutch government approved licences of the month of January 2020, the ranking is based on intended end use, of the dual use goods.

Image 1.2:  Chart; overview of number of approved licences for dual use goods; ranking based on intended end use of the goods (January 2020); data based on monthly reporting of exports of dual-use goods of Dutch government.[5]

Afbeelding met object Automatisch gegenereerde beschrijving


February 2020

In February 2020 the Dutch government approved 111 licenses[6] for dual-use goods, with a total value of EUR 390,144,786.91. The average value of a dual-use good was in the month of February 2020: EUR 3,514,817.90. The most expensive license was for dual use “information security equipment and software”. The approved license had a value of EUR 60,000,000.00 and was destined for an information security-related end use, in Russia.

The top three of destinations[7] / countries[8] the Dutch export-licenses were intended for in February 2020, were

  1. Saudi Arabia, with 10 by the Dutch government approved licenses,
  2. China, with 7 licenses, and
  3. Russia, with 7 licenses.

Image 1.3 contains a map of the world. The countries where the licences were destined for, are made blue. The darker the colour blue in Image 1.3, the more approved licences the country had in February 2020.

Image 1.3:    Map of the world; overview of number of approved Dutch licences for dual use goods; destinations / countries (February 2020); data based on monthly reporting of exports of dual-use goods of Dutch government.[9]

Afbeelding met man, berg Automatisch gegenereerde beschrijving

With regard to the kind of products / goods the licenses have been issued for, one can say the following: there were 26 different kind of export licences approved in February 2020, with a total number of 111 licences, hence:

  • 37 out of the 111 licenses where for “Information security equipment and software”;
  • 19 out of the 111 licenses where for “Information security equipment”;
  • 12 out of the 111 licenses where for “Information security software”;
  • 8 out of out of the 111 licenses where for “Information security equipment, software and technology”.

With regard to the intended purpose of end-use the licenses have been issued for, one can say the following: there were 25 different kind of export licences approved in February 2020, with a total number of 111 licences:

  • 80 times the end-use of the dual-use product was defined as “information security”;
  • 2 times the good was destined for the “chemical industry”;
  • 2 times the good was destined for the “pharmaceutical industry”;
  • 2 times the good was destined for the “hydrographic and geographical measurements”.

Image 1.4 contains a chart with all of the by the Dutch government approved licences of the month of February 2020, the ranking is based on intended end use, of the dual use goods.

Image 1.4:    Chart; overview of number of approved licences for dual use goods; ranking based on intended end use of the goods (February 2020); data based on monthly reporting of exports of dual-use goods of Dutch government.[10]

Afbeelding met schermafbeelding Automatisch gegenereerde beschrijving

[1] This list also contains combined licences, for multiple countries.

[2] A dual use licence can also be granted an a temporary / transfer base, meaning that a dual use good passes through country A, temporary stays there, and then continues to country B, for its final destination. For example: on the 28th of January 2020, the Dutch government approved a license for an image intensifier tube. The dual use good was destined for Spain, but passed through Israel. For the ranking of the countries, each country received a separate point.

[3] For the ranking of countries for which the most dual use licences were approved in a month, countries who were part of a combined licence, where valued separately. For example: the above-mentioned licence for “uranium hexafluoride” was for four different countries: Canada, Japan, the United States and South Korea. For the ranking of the countries, each country received a separate point.

[4] https://www.rijksoverheid.nl/documenten/rapporten/2016/10/01/overzicht-dual-use-vergunningen, accessed 21 March 2020.

[5] https://www.rijksoverheid.nl/documenten/rapporten/2016/10/01/overzicht-dual-use-vergunningen, accessed 21 March 2020.

[6] This list also contains combined licences, for multiple countries.

[7] A dual use licence can also be granted an a temporary / transfer base, meaning that a dual use good passes through country A, temporary stays there, and then continues to country B, for its final destination. For example: on the 19th of February 2020, the Dutch government approved a license for “secure computer equipment”. The dual use good was destined for Azerbaijan, but passed through Switzerland. For the ranking of the countries, each country received a separate point.

[8] For the ranking of countries for which the most dual use licences were approved in a month, countries who were part of a combined licence, where valued separately. For example: on the 26th of February 2020, the Dutch government approved a license for “information security software”. This software was destined for: China, Hong Kong, Macau and Taiwan. For the ranking of the countries, each country received a separate point.

[9] https://www.rijksoverheid.nl/documenten/rapporten/2016/10/01/overzicht-dual-use-vergunningen, accessed 21 March 2020.

[10] https://www.rijksoverheid.nl/documenten/rapporten/2016/10/01/overzicht-dual-use-vergunningen, accessed 21 March 2020.

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