Do I need an export licence from the UAE to ship dual-use electronics to Turkey?

There are many regulations and restrictive instructions regarding businesses, and in order to respond to you legally, please specify the type of advanced networks.

Dear Sir/Madam,

You requested guidance regarding exporting advanced networking equipment from a Dubai-based trading company to Turkey. The UAE regulates 'dual-use' electronics under Federal Decree-Law No. 43 of 2021 on Commodities Subject to Non-Proliferation Controls. The Executive Office for Control and Non-Proliferation (EOCN) oversees the export of 'Strategic Goods' (dual-use items).

Licensing: whether you require an export license depends on the technical specifications of your networking equipment. The UAE National Control List mirrors regimes like the Wassenaar Arrangement; advanced networking gear typically falls under Category 5 (Telecommunications and Information Security). Trigger for licensing: If your hardware features high-level encryption (exceeding 56-bit DES or equivalent) or high-speed switching capabilities designed for infrastructure use, it is likely classified as a controlled item. If the item is controlled, exporting without an export permit from the EOCN is prohibited, with penalties including fines up to AED 1,000,000 and possible imprisonment.

Impact of UAE–Turkey CEPA: The CEPA reduces tariffs but does not exempt security and non-proliferation controls; you must comply with all EOCN licensing requirements.

Mandatory Due Diligence & Documentation: UAE exporters must perform KYC checks. You should obtain an End-User Certificate (EUC) from your Turkish customer stating final destination, end-use, and a guarantee that the items will not be re-exported or used for military purposes; sanctions screening against the UAE Local Terrorist List and the UN Security Council Sanctions List; maintain full technical documentation (Technical Data Sheet) to justify classification; and be prepared for audits.

Catch-All Provision: Even if an item is not on the control list, a permit may be required if the exporter has reason to suspect the items may be used for military activities or prohibited end-users.

In summary, export of dual-use goods in the UAE is strictly regulated, and you should conduct due diligence, verify licensing requirements based on your product's specifications, and obtain appropriate EUCs and screenings before shipping.