Do I need an export licence in Denmark to ship dual-use sensors to Turkey?

In Denmark
Last Updated: Apr 4, 2026
I run a small Danish company and a customer in Turkey wants us to ship industrial sensors that might be classed as dual-use. I’m unsure if an export licence is required and what checks we must do on the buyer and end-use. What steps should we take to stay compliant?

Lawyer Answers

Serka Law Firm

Serka Law Firm

Apr 4, 2026
Not automatically, but very possibly yes. For a Danish exporter, the real question is not simply whether the destination is Turkey, but whether the sensor is controlled under Annex I of EU Regulation 2021/821, or whether a non-listed item is still caught by the catch-all or cyber-surveillance rules. The Danish export-control authority says the analysis turns on three things: the EU control list, catch-all, and technical assistance. For industrial sensors, the first places to check are usually Category 6, sensors and lasers, and sometimes Category 7, navigation and avionics. First, classify the exact sensor model against the current EU dual-use list using the full technical datasheet, not the marketing description. Second, identify the real buyer, consignee, end-user, installation site, and exact end-use. Third, obtain a proper Danish end-use certificate from the final end-user. Denmark’s template is used for all dual-use exports, it must state whether the end-user is civil or military, and it should be dated, stamped, and signed. Fourth, check export restrictions in TARIC and the EU Sanctions Map, and if anything is unclear ask the Danish Business Authority, which expressly says it can provide information about critical end-users, denials, and whether an application is needed. If the sensor is listed in Annex I, an export authorisation is required. Even if it is not listed, authorisation can still be required where there is a WMD risk, an embargo-related military end-use issue, or, for certain non-listed cyber-surveillance items, a human-rights/internal-repression risk. If a licence is needed, the application goes to the Danish Business Authority through Virk. Denmark states that individual licences are used for one-off orders, critical countries or end-users, and catch-all cases, while global authorisations are used for repeat exports to less critical destinations or end-users. Technical assistance, meaning transfer of sensitive know-how, can also itself be controlled in some cases. So the compliant approach is: classify first, verify the actual end-use and end-user, document that with an end-use certificate, screen the transaction, and file before export whenever there is any serious Annex I or catch-all question. Shipping first and asking later is the wrong sequence here.
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