UK Export Regulations for IT: SPIRE, OGEL, and SIEL

From data centers in London to Arm’s Cambridge-designed chips, the UK plays a critical role in global technology. When that hardware ships abroad, it’s more than a transportation concern; it’s a regulatory one. Devices with encryption—like firewalls, switches, and secure storage systems—can be used for both civilian and military purposes, which often brings them under the UK’s dual-use export controls.

The UK government manages dual-use export controls through SPIRE, a web portal where exporters register for the appropriate licenses. In this guide, we’ll cover the essentials: how to determine whether your hardware is regulated, which licenses may apply, and how to prevent customs delays. Wherever your IT hardware is headed, understanding SPIRE helps keep your rollout smooth and on schedule.

What Is SPIRE?

SPIRE is the UK government’s export licensing portal. It’s administered by the Export Control Joint Unit (ECJU), the UK authority responsible for regulating strategic exports and enforcing dual-use controls. 

The SPIRE platform is where exporters register their company, apply for licenses, and notify the ECJU before the first shipment. 

How SPIRE Classifies IT Hardware

Before you can apply for an export license, you’ll need to confirm whether your equipment appears on the UK’s Strategic Export Control Lists. These lists organize dual-use goods into numbered categories called Export Control Classification Numbers (ECCNs). For IT hardware, the most common categories include:

• Category 3: Electronics and components

• Category 4: Computers and processors

• Category 5: Telecommunications and information security

Devices that include encryption—like firewalls, switches, and secure storage systems—often fall into Category 5 (with the ECCN 5A002), a designation that signals they may be subject to dual-use export controls. 

Get Your Device’s Classification From the Manufacturer

Only the IT hardware’s manufacturer can provide an official export classification. Most major OEMs (such as Cisco, Dell, Palo Alto Networks, etc.) have already classified their products and can provide this information upon request.

Many manufacturers will follow U.S. export rules. Your IT hardware might be classified under a U.S. ECCN like 5A992, commonly used for lower-level encryption. However, the UK does not recognize 5A992 as a valid classification. 

If the manufacturer hasn’t provided a UK-specific ECCN, you may need to submit a classification request through SPIRE. 

Check If Your Shipment is Eligible for OGEL

If your hardware falls under export control, your next step is to check whether it qualifies for an Open General Export Licence (OGEL). OGELs are the UK’s streamlined export permits. They’re designed to reduce administrative burden for low-risk shipments, allowing you to export controlled items to pre-approved destinations without needing a full license for every shipment. You can use the OGEL Checker tool to see if your shipment qualifies. The following OGELs are commonly used for IT equipment:

• OGEL for Exports to the EU: Covers all EU member states. If shipping to the EU, you must use this OGEL

• OGEL GA0001 (General Export Authorisation 001): Covers exports to select non-EU countries, including the U.S., Canada, Japan, Australia, New Zealand, and Switzerland

• OGEL for Information Security Items: Covers a wider range of destinations than the other OGELs, with tighter restrictions. You can’t use it if the end user is a government or military entity, or if you’re shipping to destinations like China, Hong Kong, or the UAE

These licenses come with specific eligibility rules and often exclude shipments involving:

• Military or government end users

• Use in nuclear, chemical, or biological weapons

• Destinations in special economic zones or bonded warehouses

If you’re using an OGEL, you must notify the ECJU before your first export under that license. This will be a formal notice to the UK government that you intend to use the license and that your shipment complies with its terms. You’re also required to do the following:

• Keep detailed records for each shipment, including classification documents and end-use details

• Submit annual reports summarizing your OGEL activity

• Make sure your shipping agent includes the correct license code on the export declaration

The ECJU may follow up with a site visit after your first OGEL registration to verify that your company understands the license terms and has proper controls in place to manage compliance.

If your shipment qualifies, OGELs are by far the most efficient licensing option. However, if no OGEL fits your destination, end user, or use case, you’ll need to apply for an individual export license.

If OGEL Isn’t an Option, Apply for a SIEL

If your shipment doesn’t qualify for any OGEL (e.g., you're exporting to a country not covered by an OGEL, you’ll need to apply for a Standard Individual Export Licence (SIEL). A SIEL is an export license issued on a case-by-case basis for an individual shipment and recipient.

Unlike OGELs, which are pre-approved and reusable, SIELs require a full government review and supporting documentation. This includes technical specs for the equipment, details about the end user, and a signed End-User Undertaking. The documentation needs to confirm the goods won’t be used for military or other prohibited purposes.

SIEL applications go through SPIRE and are usually processed in 30 to 45 working days. Delays in classification or missing documents can push your timeline back by weeks, so it’s best to start the SIEL application process early. If you expect to export similar equipment repeatedly to the same client or region, you may want to consider a more flexible license type.

For Frequent Shipments, Apply for an OIEL

If you regularly export similar equipment to the same end users, an Open Individual Export Licence (OIEL) may be a better fit. An OIEL covers multiple shipments over a set period, without requiring a new application each time. It requires more documentation upfront and takes longer to approve than a SIEL. 

Once approved, an OIEL offers greater flexibility and reduces the licensing burden for repeat shipments.

Using an Exporter of Record Provider Can Simplify the Process

If your team doesn’t have the capacity or in-house expertise to manage UK export licensing, working with an Exporter of Record (EOR) can help. A third-party EOR provider serves as the legal exporter on your behalf, handling compliance, licensing, and documentation so you don’t have to.

In many cases, the EOR provider already holds the necessary OGELs and can process your shipment under their license as long as your destination and end user meet the conditions. This can be especially helpful if you export infrequently or want to avoid the overhead of SPIRE registration and reporting.

To work with an EOR provider, you’ll typically sign documents that establish the relationship and authorize them to act on your behalf. The EOR provider will then manage the licensing, prepare the export declaration, and ensure all codes and documents are submitted correctly.

Working with an EOR provider doesn’t remove your compliance responsibilities entirely. You’ll still need to provide accurate classification and end use details. However, it can streamline the process and reduce your risk, especially when shipping to destinations with more complex licensing.

What Happens If You Don’t Comply?

If your shipment includes dual-use equipment and lacks the proper license, UK customs can hold it without warning. This usually happens after your shipping provider submits the export declaration, as your goods are about to leave the country.

When a shipment is flagged, ECJU may place it on hold pending a review. The EOR will receive a formal request for documentation, which often includes the product classification, technical specifications, and a clear explanation of the end use and destination.

If you lack the proper license, you’ll be reacting rather than planning. The review process can take days or even weeks, especially if you need to request a classification or submit a last-minute SIEL application. Sometimes, the ECJU will release the shipment once the paperwork checks out. In other cases, you may be asked to recall it entirely.

This is where the absence of a UK-specific ECCN can cause serious delays. As previously mentioned, many U.S.-based manufacturers will only provide U.S. classifications, like 5A992, which the UK does not recognize. If you’re stuck without a valid classification or license, you’ll need to wait for the government review to run its course.

The better path is proactive: secure the classification, confirm your license type (OGEL or SIEL), register early, and make sure your shipping agent includes the correct license codes on the paperwork. A bit of preparation can prevent weeks of delays at customs.

Key Takeaways for Exporting from the UK

If you’re exporting IT hardware from the UK, dual-use controls can quickly complicate an otherwise routine shipment. With the right classification and licensing approach, you can avoid delays and move smoothly through customs. Here’s what to keep in mind when preparing your export:

• Start with the manufacturer. Ask for the UK-specific export classification for the hardware you're shipping. U.S. ECCNs like 5A992 won’t help you in the UK.

• Check for OGEL eligibility. If your shipment qualifies for an OGEL, register in SPIRE, notify the ECJU, and follow the terms carefully.

• Apply for a SIEL if needed. For destinations like India, Hong Kong, or the UAE, you may need a SIEL. Approval usually takes 30 to 45 working days.

• Understand your responsibilities. Even when using an OGEL, your team must handle reporting, recordkeeping, and compliance. The shipping provider is not responsible for these requirements.

• Consider using an Exporter of Record. If you don’t have the resources to manage licensing, an EOR can ship under their OGEL and handle the paperwork for you.

• Take a thorough approach to export compliance. If your shipment is flagged, you’ll need to prove compliance afterward, which can lead to delays, audits, and unexpected setbacks.

With early planning and the right support, you can navigate SPIRE regulations and keep your shipments moving, wherever in the world your hardware is headed.

Many multinational enterprises trust FGX to deliver seamless, best-in-class global IT shipping solutions for their infrastructure. We provide coverage to 174 countries and maintain a 99.98% customs clearance and delivery success rate even in highly regulated markets such as Brazil, India, and China. Please reach out if you’re interested in learning more.