Dual-use export licence (individual, global or EU general export authorisation)

Dual-use export licence (individual, global or EU general export authorisation) is filed with Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061). With Managora you do it 100% online: you answer a few questions, sign a digital mandato (power of representation) and we draft, sign and file your application for you. What we charge you: from €299. Official tasa (government fee): No official fees: neither Ley 53/2007 nor RD 679/2014 sets any fee for the licence, for the notice of use of a general authorisation or for REOCE registration. If the JIMDDU requires the end-use statement to be endorsed by the authorities of the destination country, whatever those authorities charge is set by that country and is not included in the price. Taxes and costs of the export customs clearance are not part of this service either.

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We check whether your product, software or technology is on the dual-use list or caught by the catch-all clause, and handle the route that applies to you: the notice to use an EU general export authorisation, the individual licence or the global licence with its internal compliance programme. We prepare the control documents, register your company with the REOCE if it is not yet registered, and file the application with the Secretaría de Estado de Comercio under your authorisation, following it up until the decision. The export customs declaration is lodged by your company or by a registered customs representative; we leave the licence details ready for it.

Practical guide: Dual-Use Export Licence in Spain: Product Classification, REOCE Registration, JIMDDU and Deadlines. Requirements, deadlines and the steps, explained.

What we charge you: from €299
Managora's fee: €299.00 (21% VAT incl.)
Tasa (official government fee): No official fees: neither Ley 53/2007 nor RD 679/2014 sets any fee for the licence, for the notice of use of a general authorisation or for REOCE registration. If the JIMDDU requires the end-use statement to be endorsed by the authorities of the destination country, whatever those authorities charge is set by that country and is not included in the price. Taxes and costs of the export customs clearance are not part of this service either.
Processing time: Licences: the Secretaría de Estado de Comercio decides within a maximum of 6 months, with a report from the JIMDDU; if it does not notify a decision in that time, the application is deemed refused (negative silence). If the company first has to be registered with the REOCE, registration is decided within 60 working days and the licence is applied for afterwards. The individual licence is valid for 12 months and the global licence for 3 years. EU general export authorisation: the notice is filed at least 10 days before the first shipment.
Where it is filed: Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061) ↗
What you receive: Application

Cost breakdown: EU general export authorisation 299 € (VAT included): notice of use of a general authorisation EU001 to EU008 and template register of transactions. Individual licence 699 € (VAT included). Global licence with internal compliance programme 1.499 € (VAT included). For licences, if your company is not registered with the REOCE, 199,00 € is added for the registration, which we handle before applying for the licence. No official fees..

Dual-use export licence (individual, global or EU general export authorisation): how is it filed?

1Answer the questions (around 15 minutes) and upload the data sheet and, if you are applying for a licence, the contract or the order.
2If your answers show that you do not need a dual-use licence or that the transaction cannot be authorised (destination Russia or Belarus, sanctioned consignee), we tell you before you pay.
3Payment: EU general export authorisation 299 €; Individual licence 699 €; Global licence with internal compliance programme 1.499 € (VAT included). If your company is not registered with the REOCE, 199 € is added.
4We check whether your product is in Annex I to Regulation (EU) 2021/821 and under which code, or whether the catch-all clause applies, and which route fits. If the route you chose does not work for you, we tell you before preparing anything.
5Your legal representative signs the mandate and registers Managora as representative in the Secretaría de Estado de Comercio application (the «Registro de Representantes» option); we guide you step by step. We never ask for your digital certificate.
6If the company is not registered with the REOCE, the registration is applied for first: we prepare all of it and file it under your authorisation (if the application does not allow you to register us as representative before your company is registered, your legal representative files it with what we leave ready). The Secretaría de Estado de Comercio decides within 60 working days, with a report from the JIMDDU, and the licence cannot be applied for until then.
7Licences: we prepare the end-use statement form for the final consignee to sign, the sheet on non-EU components if needed and, for a global licence, the internal compliance programme; we file the application under your authorisation and answer any requests until the decision.
8General authorisation: we draft the notice with your undertakings, your legal representative signs it and we file it at least 10 days before the first shipment; we give you the template register of transactions and the wording that invoices and transport documents must carry.
9The export customs declaration is lodged by your company or by a registered customs representative; we leave ready the licence or general authorisation details that must appear on it, and remind you of the obligations that follow: sending the half-yearly report of clearances and keeping the documentation.

Which documents do you need?

•Data sheet of the product, software or technology, with the parameters that allow it to be classified on the dual-use list.
•For licences: contract, order or pro forma invoice for the transaction (for a global licence, the contract proving the relationship with the consignees). If the authorities have informed you that your product needs a licence, a copy of that notice.
•For licences: end-use statement signed by the final consignee, with the undertaking not to re-export without authorisation. We prepare the official form and, if the JIMDDU requires it, it is endorsed by the authorities of the destination country.
•For a global licence: internal compliance programme (we review yours or draft it).
•For the EU general export authorisation: the notice setting out the undertakings of use, which we draft and your legal representative signs.
•If the company is not registered with the REOCE: deed of incorporation and power of attorney of whoever signs, and the sworn statement that goes with the registration, which we draft.

Prerequisites we also handle for you

And whatever a third party provides, we arrange it

Traducción jurada (sworn translation) into Spanish
Apostilla or legalisation of a foreign document

You do not have to look for anyone: we coordinate it. As it is provided by a third party it is quoted separately and does not go inside the price of this procedure, and we tell you the amount before ordering it.

Legal basis and things to bear in mind

Authorisation is required to export any product, software or technology listed in Annex I to Regulation (EU) 2021/821, and also an unlisted product when the authorities inform the exporter that it may be intended for chemical, biological or nuclear weapons, their missiles, or a military end use in a country under an arms embargo. If the exporter knows it is going to one of those uses, it must notify the authorities, who decide. This is determined by the product's technical features, not its tariff heading, and sending software or technology electronically outside the EU is also an export.
Only operators registered with the REOCE can apply for a licence, and only people and businesses resident in Spain can register. Registration is decided within 60 working days, after a report from the JIMDDU, and any change to the registered details must be notified within 30 working days.
Licences are decided by the Secretaría de Estado de Comercio, with a mandatory and binding report from the JIMDDU, within a maximum of 6 months; if no decision is notified in that time, the application is deemed refused. The individual licence is valid for 12 months and the global licence for 3 years, and each can be extended at most twice, by applying for a rectification.
To use an EU general export authorisation you must notify the Secretaría de Estado de Comercio in writing at least 10 days before the first shipment, export only the items and destinations it covers and keep an individual record of each export: description and Annex I code, quantities and dates, exporter, consignee and user, public or private nature of the end user, end use and percentage of listed components originating outside the EU.
The holder of an authorisation sends the Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso, every six months, the clearances of the previous half-year, or a statement that no transactions took place, and keeps all the documentation for 10 years from the expiry of the authorisation.
EU sanctions prohibit exporting dual-use items to Russia or for use in Russia. Exporting dual-use items without authorisation, or with one obtained using false information, is the criminal offence of smuggling from 50.000 euros; below that it is an administrative offence, with a fine of 200 to 350 % of the value (minimum 1.000 euros).
The Secretaría de Estado de Comercio decides whether to grant it: we cannot guarantee it. A refusal can be appealed; the Managora law firm handles it, as a separate engagement quoted in advance.

Dual-use export licence (individual, global or EU general export authorisation): frequently asked questions

Dual-use export licence (individual, global or EU general export authorisation): how much does it cost?

We charge you from €299: our fee plus, where applicable, the fixed official tasa we advance. EU general export authorisation 299 € (VAT included): notice of use of a general authorisation EU001 to EU008 and template register of transactions. Individual licence 699 € (VAT included). Global licence with internal compliance programme 1.499 € (VAT included). For licences, if your company is not registered with the REOCE, 199,00 € is added for the registration, which we handle before applying for the licence. No official fees.. Managora's fee is €299.00, 21% VAT included (€247.11 net + €51.89 VAT). The official tasa charged by the authority (a suplido paid on your behalf, no VAT) is: No official fees: neither Ley 53/2007 nor RD 679/2014 sets any fee for the licence, for the notice of use of a general authorisation or for REOCE registration. If the JIMDDU requires the end-use statement to be endorsed by the authorities of the destination country, whatever those authorities charge is set by that country and is not included in the price. Taxes and costs of the export customs clearance are not part of this service either..

Dual-use export licence (individual, global or EU general export authorisation): how long does it take?

Licences: the Secretaría de Estado de Comercio decides within a maximum of 6 months, with a report from the JIMDDU; if it does not notify a decision in that time, the application is deemed refused (negative silence). If the company first has to be registered with the REOCE, registration is decided within 60 working days and the licence is applied for afterwards. The individual licence is valid for 12 months and the global licence for 3 years. EU general export authorisation: the notice is filed at least 10 days before the first shipment.

Dual-use export licence (individual, global or EU general export authorisation): which documents do I need?

You need to have to hand: Data sheet of the product, software or technology, with the parameters that allow it to be classified on the dual-use list., For licences: contract, order or pro forma invoice for the transaction (for a global licence, the contract proving the relationship with the consignees). If the authorities have informed you that your product needs a licence, a copy of that notice., For licences: end-use statement signed by the final consignee, with the undertaking not to re-export without authorisation. We prepare the official form and, if the JIMDDU requires it, it is endorsed by the authorities of the destination country., For a global licence: internal compliance programme (we review yours or draft it)., For the EU general export authorisation: the notice setting out the undertakings of use, which we draft and your legal representative signs., If the company is not registered with the REOCE: deed of incorporation and power of attorney of whoever signs, and the sworn statement that goes with the registration, which we draft.. You do not upload them here: we collect the details through the guided chat.

Who files the procedure?

Managora files it in your name with Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061). You only provide the details through the chat and sign a mandato (power of representation); we prepare, sign and register it.

Can it be done online?

Yes. The whole process is online: you answer a few questions in the guided chat, sign a simple mandato on screen and receive the receipt and the official documents by email, with full legal validity.

Related procedures

Based on the legislation in force and on the official site of the competent authority: Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061) ↗.

Managora Gestion SL (company number B88823893) is a private company. We are not Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061), we are not affiliated with, authorised or endorsed by any public authority, and this website is not an official government portal. What you pay on this page is our fee for preparing, signing and filing the procedure on your behalf: it is separate from the official tasa, which where applicable belongs to the authority and is shown to you separately. You can carry out this procedure yourself, directly with Secretaría de Estado de Comercio, Subdirección General de Comercio Internacional de Material de Defensa y Doble Uso (formularios de licencias y REOCE, SIA 991061).

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