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

Yes, potentially. If your electronics fall within Annex I of EU Dual-Use Regulation 2021/821, an export authorisation is required before shipping them from Belgium to a non-EU country. The EU control list is updated regularly, and Annex I was updated again in September 2025. Turkey is not automatically a prohibited destination under the EU dual-use regime. In practice, the answer depends on three points: how the product is classified, who the Turkish end-user is, and what the declared end-use is. The EU also has general export authorisations for certain items and destinations, and Turkey appears on the destination lists for some of them, but those authorisations only apply if all item, destination, and end-use conditions are actually met. Even if the item is not listed in Annex I, a licence can still be required under the EU catch-all rules if the goods may be connected to weapons of mass destruction, a military end-use or end-user, public security concerns, or, in some cases, cyber-surveillance uses linked to internal repression or serious human-rights abuses. Because your company is in Antwerp, the competent Belgian authority is the Flemish Strategic Goods Control Unit. In Belgium, dual-use export licensing is handled by the regional authority linked to the exporter’s place of establishment. Before shipping, the usual legal review is: product classification against Annex I, review of any related software, firmware, or technology, verification of the Turkish buyer and ultimate end-user, confirmation of the civilian end-use, sanctions and denied-party screening, and diversion-risk checks, especially where there is any risk of re-export to Russia or another restricted destination. The European Commission expects exporters to apply risk-based due diligence and has issued specific anti-circumvention guidance for exports routed through third countries. The practical paperwork usually includes technical datasheets, a classification memo, commercial documents, an end-use and end-user statement, customer identification details, and, where needed, the export licence application itself. If the goods are controlled, they should not be shipped until the correct licence basis is confirmed, whether through an individual licence, a global licence, or a valid general authorisation. So the short answer is: yes, a Belgian export licence may be required, but not simply because the destination is Turkey. The real issue is whether the electronics are controlled and whether the customer, end-use, and re-export risk pass proper screening.