Do I need an export licence from Austria to sell dual-use sensors to Turkey?

In Austria
Last Updated: Mar 3, 2026
I run a small company in Vienna and a buyer in Turkey wants to order industrial sensors that might be considered dual-use. I’m unsure if EU export control rules apply and what documents I need before shipping. What are the risks if I ship without the right licence?

Lawyer Answers

Kule Hukuk Bürosu

Kule Hukuk Bürosu

Mar 3, 2026

Thank you for consulting us regarding your upcoming shipment. Because you are dealing with industrial sensors—which are frequently classified as "dual-use" items (usable for both civilian and military purposes)—this requires careful adherence to EU Regulation 2021/821 and Austrian export laws.


Here is the breakdown of the regulations, risks, and necessary documentation you asked about:


1. Do EU Export Rules Apply?


Yes. Even though Turkey and the EU share a Customs Union, dual-use goods are excluded from the free movement of goods.




  • If your sensors are listed in Annex I of the EU Dual-Use Regulation, you legally must obtain an export license from the Austrian authority (BMAW) before shipping.




  • Even if they are not listed, "Catch-All" clauses may apply if there is any suspicion the items are intended for military end-use.




2. What are the Risks of Non-Compliance?


Shipping without the correct license is a serious offense. The risks include:




  • Customs Seizure: The shipment will be blocked at the Austrian or Turkish border.




  • Legal Penalties: In Austria, violations of the Foreign Trade Act (Außenwirtschaftsgesetz) can lead to severe fines and even criminal liability (prison sentences) for the managing directors.




  • Blacklisting: Your company could be placed on a "Denied Parties" list, preventing you from trading internationally in the future.




3. Required Documents


To apply for the license and clear customs safely, you will immediately need:




  • End-User Certificate (EUC): A formal document signed by the Turkish buyer stating clearly what the sensors will be used for and confirming they will not be diverted to military use.




  • Technical Data Sheets: To determine the correct Export Control Classification Number (ECCN).




  • Company Profile: Details on the Turkish buyer to screen against sanctions lists.




Next Steps


Given the complexity of dual-use classification and the severity of the penalties, we need to review the technical specifications of your sensors immediately to determine the correct license path.

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